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Income Taxes
6 Months Ended
Jun. 30, 2025
Income Tax Disclosure [Abstract]  
Income Taxes
22. Income Taxes
For the three and six months ended June 30, 2025, the effective tax rates on pre-tax income were 19.8% and 25.8%, respectively. For the three month period, the effective tax rate is not materially different from the statutory rate of 21%. For the six months ended June 30, 2025, the effective tax rate is higher than the statutory rate of 21% due to pre-tax losses incurred during the period, which generated a tax benefit, and normal tax benefits that further increased our tax benefit.
For the three and six months ended June 30, 2024, the effective tax rates on pre-tax income were 688.1% and (257.4)%, respectively. For both periods, the Company’s effective tax rate was different from the statutory rate of 21% as a result of a deferred tax benefit related to the Bermuda corporate income tax.
Pillar Two and Bermuda Corporate Income Tax Regime
In December 2023, the Government of Bermuda enacted a corporate income tax (“CIT”) regime, designed to align with the Organization for Economic Cooperation and Development's ("OECD's") global minimum tax rules. The Corporate Income Tax Act 2023 came into operation in its entirety on January 1, 2025. The regime applies a 15% CIT to Bermuda businesses that are part of MNE groups with annual revenue of €750 million or more, including us. As of June 30, 2025, we had a deferred tax asset of $336 million relating to this regime.
The Company continues to evaluate the impact of the global minimum tax requirements by monitoring the legislative changes and future developments in relation to Pillar Two across jurisdictions in which the Company operates and assessing their impact on our operations and financial statements.
Other Tax Matters
On July 4, 2025, the One Big Beautiful Bill Act (the “OBBBA”) was enacted in the U.S. The OBBBA includes provisions that allow for the immediate expensing of domestic research and development expenses, immediate expensing of certain capital expenditures and other changes to the U.S. taxation of profits derived from foreign operations. The Company continues to evaluate the impact the new legislation will have on our estimated annual effective tax rate and cash tax position.