Although Bermuda-based groups and companies continue to adapt to the effects of BEAT, Bermuda will need to do more to attract and keep re/insurance businesses on the island. It is certainly the case that Bermuda has an impressive infrastructure for the re/insurance market. But with its tax advantage diminished after the US tax law changes at the end of 2017, and with Bermuda's regulatory advantages having diminished over time it will have to work hard to compete in the global competition for re/insurance business. That is, to present a strong, positive case as to why business should come to its shores.
Schneider said in a Jan. 23 Fitch Ratings report that while the U.S. tax law would “significantly reduce the long-standing Bermuda tax advantage over the U.S.,” the “overall benefit of maintaining a Bermuda market domicile and operations will likely endure, albeit at a decreased level.”
https://www.bna.com/bermuda-insurers-reinsurers-n57982092593/