PPLI Jurisdictions: Compare Rules, Tax and Protection
Compare the legal issuer, policyholder protection, investment rules and cross-border constraints. For U.S. persons, a foreign domicile does not itself establish U.S. insurance qualification or product availability. Explore Luxembourg, Liechtenstein and the Swiss planning context, then use the comparison tools and jurisdiction research below. Check the cited evidence and its date for the specific issuer and policy being considered.
Compare the rules behind the policy
Answer ten questions and see seven insurer domiciles ranked for your profile, with the figures and sources behind each rank. Nothing you enter leaves your browser and no email address is required.
The worked example and the full comparison below remain available if the selector does not load.
Read the contract, then compare the jurisdiction
Carrier domicile is one part of the decision
Compare the issuing insurer, policy terms, account structure and relevant tax systems together. A domicile can change the supervisory framework and creditor rights. It does not establish the policyholder's tax treatment, permission to buy the policy or access to a particular investment.
The selector above asks ten questions and ranks seven insurer domiciles for your profile: the United States (Delaware), Bermuda, the Cayman Islands, Luxembourg, Liechtenstein, Ireland and Singapore. Each rank comes from eight criteria scored from the sourced facts on this page, and the weights, scores and any constraint are shown under the result. The full comparison table below covers the first four in twenty dimensions.
Why jurisdiction matters
Account structure, investment authority, taxation and cross-border servicing are separate questions.
Identify the issuing entity and legal structure
Start with the legal name on the policy. A group brand, office address or regulator register entry does not establish the terms of a particular offer. Ask which entity owes the benefit, who owns the assets, which liabilities may reach them and what changes in insolvency.
- Delaware: Section 2932(a)(5) treats separate-account assets as insurer-owned. Insulation depends on the contract and covers only the portion representing reserves and other contract liabilities. It is not personal ownership of the underlying securities, and the guaranty association (US$300,000 death benefit, US$100,000 cash value) excludes values where the owner bears the investment risk.
- Bermuda: determine whether the actual insurer uses the Segregated Accounts Companies Act. Allocation, written recourse terms and internal transactions matter under Sections 9, 12, 17 and 17A. Bermuda has no policyholder compensation scheme.
- Cayman Islands: identify whether the structure is an SPC, a separate PIC or another arrangement. Section 221 conditions secondary recourse to general assets on a portfolio shortfall, the articles and required minimum capital. Insurance Act Section 29 separately protects long-term policy proceeds from the policyholder's creditors.
- Luxembourg: examine the asset inventory, deposit agreement and claim priority. Article 118 of the insurance-sector law gives policyholders a privilege over the cover assets that ranks ahead of all others once they are on the permanent inventory, and Article 253-5 gives unit-linked creditors first rank on their units in a winding-up. CAA custody rules add conditions and exceptions. There is no life compensation scheme.
The full comparison links each of these statements to its source. Insurer-creditor protection and protection against a policyholder's own creditors are different inquiries.
Match investment rights to the applicable tax rules
A fund permitted by the local insurance framework is not automatically acceptable under US tax rules. Evaluate Sections 7702 and 7702A, Section 817(h) diversification and the investor control doctrine separately. A label such as IDF, SMA or specialized insurance fund does not settle all three.
Luxembourg Circular 26/1 illustrates the distinction. Its asset categories require both a premium and a declared securities wealth, for example EUR 125,000 and EUR 250,000 for category A, and EUR 1,000,000 and EUR 2,500,000 for category D. A specialized insurance fund can involve selection rights that need separate US investor-control review. Passing a local investment limit does not answer that question.
Determine the actual tax and servicing facts
Premium tax can depend on the location of the risk, the relevant state or country, policy type, the insured life and the issuer. A Delaware insurer does not automatically produce a US$2,000 tax charge: that cap applies only to trust-owned, single-life private placements on Delaware risks. A foreign owner does not automatically remove US foreign-insurance excise exposure.
Before a purchase or move, obtain country-specific advice on solicitation, delivery, continued servicing, additional premiums, distributions, death benefits and reporting. If the issuer cannot document the required service or investment arrangement, the domicile comparison cannot fill that gap.
A worked example: US$25 million of premium
Conditional arithmetic for specific tax components, with omitted charges identified.
Assume US$25 million of taxable net premium, entered as an exact amount in the tool. For the qualifying Delaware private-placement example, also assume a trust-owned single-life policy, federal private-placement status and all applicable delivery and tax-allocation conditions. For the foreign examples, separately assume an in-scope life policy under Sections 4371 and 4372 and no established exemption.
A US-person answer alone does not establish these facts. To reproduce the Delaware Section 702(c)(3) and excise rows in the selector, choose a trust owner, an insured US person and a single premium, and enter US$25,000,000 as the exact amount.
| Selected scenario | Arithmetic | Illustrated component |
|---|---|---|
| Delaware Section 702(c)(1), general schedule | US$25,000,000 × 1.75% | US$437,500 |
| Delaware Section 702(c)(2), first-year per-case schedule | US$10,000,000 × 2% + US$15,000,000 × 1.5% | US$425,000 |
| Delaware Section 702(c)(3), qualifying private placement | US$100,000 × 2% + US$24,900,000 × 0% | US$2,000 |
| In-scope foreign life policy, no exemption established | IRC Section 4371(2): US$0.01 × 25,000,000 dollars of premium | US$250,000 federal excise |
| Valid Section 953(d) election by the foreign issuer assumed | Selected domestic-tax treatment assumption | US$0 of the modeled federal excise |
| Qualifying Luxembourg treaty relief assumed | Treaty conditions and an effective issuer closing agreement assumed; the IRS lists read in September 2026 show no Luxembourg life insurer | US$0 of the modeled federal excise |
The three Delaware rows are alternative scenarios, not three taxes to add together. The graduated row models only the first calendar year for a case; in later calendar years the statute caps the rate at the rate established for the preceding year, and all contracts of one employer or trust are aggregated as a case. The private-placement row applies per policy per calendar year, so each later year with more than US$100,000 of premium again costs US$2,000.
The foreign rows omit local premium taxes, stamp duties and taxes imposed by other countries. Bermuda charges no premium tax on business written for non-residents, the Cayman Islands levy no premium tax and Luxembourg levies none on life insurance. No Cayman stamp duty is included; ask the insurer whether any is due on the policy documents. The policyholder's country of residence may still tax the premium.
None of these amounts includes mortality, administration, manager, custody, surrender or other policy charges. They are neither comparable full prices nor lower-bound quotes. Obtain the issuer's complete charge schedule and a country-specific tax calculation.
Sources: 18 Del. C. Section 702, IRC Section 4371, IRS Publication 510, Section 4372, Section 4373, Rev. Proc. 2003-47 and IRS treaty-relief guidance.
How to read a result
Match scores, criteria, money figures and evidence labels.
The selector ranks seven insurer domiciles from first to last for the answers you give. Each row shows a match score out of 100, a verdict that names the criterion deciding its place with the figure behind it, the three criteria that lift it most for you, each with its figure and source, and the main watch-out. The first row is open; the others open on request, with every criterion score, its reason and its citation.
- Match score: the weighted average of eight criterion scores from 0 to 10, times ten. It measures fit between your stated profile and sourced facts about each domicile. It is not a rating of an insurer, a forecast of returns or a guarantee of protection.
- Criterion scores: each is fixed in the published data with its reason and citation. Where the law leaves a point to the insurer or to market practice, the score is set cautiously and the result says so beside the figure.
- Money figures: entry taxes are computed on your premium, for example the Delaware premium tax, the US excise, Swiss stamp duty, Belgian or Austrian premium tax and Brazilian IOF where they apply. US$0 means the named charge does not arise on those facts; it does not mean the policy is free of tax or charges.
- Constraints: rules tied to your residence, such as EU freedom of services, UK promotion rules or India's RBI permission, move scores. They are listed with their sources under "How this ranking was built".
The full comparison table keeps its evidence labels. Source-supported means the cited material supports the limited statement in the field; Requires review means issuer-specific, country-specific or further primary evidence is still needed.
The full comparison: 20 rows across four jurisdictions
All eighty fields: eighteen fact rows and two summary rows, with evidence states and source or research links.
The table and interactive profiles use the same versioned dataset. A source-supported field states a documented framework, not a verified policy offer. Rows marked as different legal objects require country-specific interpretation.
| Dimension | United StatesDelaware framework | Bermuda | Cayman Islands | Luxembourg |
|---|---|---|---|---|
| Primary regulator | Delaware Department of Insurance, headed by the elected Insurance Commissioner; its Bureau of Examination, Rehabilitation and Guaranty regulates companies. The department reported 150 domestic companies with US$818 billion of assets under supervision for 2025. Identify the issuing entity and the states relevant to solicitation and delivery.Source-supportedDOI 2025 data release, Feb. 2, 2026 | The Bermuda Monetary Authority registers and supervises insurers under the Insurance Act 1978. Since March 13, 2026 the Corporate Income Tax Agency has administered CRS, and since March 31, 2026 economic substance. Check the issuing entity and its registration conditions.Source-supportedInsurance Act 1978; Economic Substance Amendment Act 2026 | The Cayman Islands Monetary Authority licenses insurers, insurance managers, brokers and agents and registers portfolio insurance companies; annual fees are due January 15. CRS is administered by the Tax Information Authority (DITC), not by CIMA.Source-supportedInsurance Act 2010; Monetary Authority Act | The Commissariat aux Assurances (CAA) supervises insurers, reinsurers, pension funds and intermediaries. It is funded by taxes on supervised entities (Article 31) and receives licence applications (Article 44(2)). Confirm the issuing entity and its authorized branches.Source-supportedLaw of 7 December 2015, Articles 7, 31, 44 |
| Statutory framework | Title 18 of the Delaware Code: premium tax in chapter 7 (Section 702), separate accounts and variable contracts in Section 2932, surplus lines in chapter 19 and the guaranty association in chapter 44. The private-placement premium-tax rate was added by HB 237, 80 Del. Laws c. 222, signed May 5, 2016.Source-supported18 Del. C. Sections 702, 2932, 1905, 4403; 80 Del. Laws c. 222 | Insurance Act 1978, last amended by the Insurance Amendment (No. 2) Act 2025 in force January 7, 2026; Life Insurance Act 1978 for contract law, last amended 2014; Segregated Accounts Companies Act 2000; Class C, D and E Solvency Requirement Rules 2011. Rule changes effective January 1, 2026 require asset and liability statements from Class C, D and E insurers.Source-supportedInsurance Act 1978 (2025:33); Life Insurance Act 1978; SAC Act 2000 | Insurance Act 2010 as amended, most recently by the Insurance (Amendment and Validation) Act 2024, in force January 1, 2025; Applications and Fees Regulations and Portfolio Insurance Companies Regulations (2026 Revisions); Capital and Solvency Regulations; segregated portfolio companies under Companies Act (2026 Revision) Sections 212 to 228A.Source-supportedInsurance Act 2010; SL 56 of 2024; Companies Act (2026 Revision) | Law of 7 December 2015 on the insurance sector (consolidated April 3, 2026); Law of 27 July 1997 on the insurance contract (consolidated November 25, 2025); CAA Circular 26/1 on unit-linked investment rules, in force February 1, 2026 and replacing 15/3 for new contracts; Circular 16/9 on asset deposit as amended by 26/2; CAA Regulation 15/03. Contracts issued before February 1, 2026 keep their prior rules unless amended (26/1 Section 10).Source-supportedLaw of 7 December 2015; Law of 27 July 1997; CAA Circulars 26/1, 26/2, 16/9 |
| Licence class | US PPLI is a variable life policy sold as a private placement to accredited investors or qualified purchasers and exempt from SEC registration; Delaware has no separate PPLI licence class. Confirm the insurer's life and variable-contract authority and its distribution permissions in each relevant state.Requires reviewIssuer-specific authorization review | Long-term Classes A and B turn on ownership and related business (Class B: at least 80% owner or affiliate business). Commercial classes turn on total assets: Class C under US$250 million, Class D US$250 million or more but less than US$500 million, Class E more than US$500 million. Class IILT is the innovation class. Registration does not certify a PPLI product.Source-supportedInsurance Act 1978 Sections 4EB to 4EF, 4EJ | Insurance Act Section 4(3): Class A domestic; Class B(i) at least 95% related business, B(ii) over 50%, B(iii) 50% or less, the class used by open-market PPLI writers; Class C collateralized reinsurance; Class D reinsurance. Long-term minimum capital: B(i) US$200,000, B(ii) US$300,000, B(iii) US$400,000. Class B insurers must appoint a licensed Cayman insurance manager.Source-supportedInsurance Act 2010 Section 4(3); Capital and Solvency (Classes B, C and D) Regulations (2018 Revision) | Prior CAA authorization is required per branch (Article 44); unit-linked life is branch III of Annex II. The one-off licence tax is EUR 10,000, plus EUR 1,000 per additional branch. No separate PPLI authorization exists; only a type N collective internal fund must be notified to the CAA before first use.Source-supportedLaw of 7 December 2015 Article 44 and Annex II; RGD of 28 April 2014 Article 2; Circular 26/1 Section 7.1.2 |
| Investment architectureDifferent legal or commercial objects | Section 2932(a)(2) lets separate-account assets be invested without regard to the investment limits for life insurers; income and losses are credited without regard to the insurer's other business, and assets are valued at market. Regulation 1205 Section 6.0 limits a variable-life separate account to 10% of its assets in any one issuer (US government securities excluded), unless the Commissioner waives it.Source-supported18 Del. C. Section 2932(a)(1), (2), (4); 18 Del. Admin. Code 1205-6.0 | No quantitative unit-linked asset list or limit applies. Under the prudent person principle an insurer may take only investment risks it can identify, measure, monitor, control and report; BMA guidance on the principle took effect July 1, 2025. Linked business usually runs through segregated accounts. Confirm the assets permitted for the policy with the insurer.Requires reviewInsurance Code of Conduct; BMA prudent person guidance, July 1, 2025 | CIMA's Investment Activities Rule sets a prudent person standard with no numeric limits: insurers must closely match assets and liabilities for unit-linked policies (6.2.5) and set minimum and maximum allocation limits in their investment policy (6.4.6). Insurance Act Section 16(3) and (4) require a separate account and segregated funds for linked policies.Source-supportedCIMA Investment Activities Rule 6.1.1, 6.2.5, 6.4.6; Insurance Act Section 16 | Circular 26/1 categories are cumulative: premium AND declared securities wealth, with premium aggregated across the client's contracts with the insurer. A: EUR 125,000 and EUR 250,000; B: EUR 250,000 and EUR 500,000; C: EUR 250,000 and EUR 1,250,000; D: EUR 1,000,000 and EUR 2,500,000; N is the default. Type N allows 10% per non-public issuer, with holdings above 5% capped at 40% in total; type C has no global or per-issuer limit within the asset catalogue; type D is unrestricted across financial instruments and bank or precious-metal accounts.Source-supportedCAA Circular 26/1 Section 2 and Annex 1 |
| IDF / SMA availabilityDifferent legal or commercial objects | Delaware sets no IDF minimum. Federal diversification under Treasury Regulation 1.817-5(b): no more than 55% of assets in one investment, 70% in two, 80% in three and 90% in four, tested at each quarter end or within 30 days. Look-through under 1.817-5(f) applies only to funds held solely by insurers' segregated asset accounts and closed to the public. A manager or SMA label is not a safe harbor.Source-supportedTreasury Regulation 1.817-5(b), (c), (f) | No statutory IDF or managed-account regime and no legal minimum premium or fund size. Segregation comes from Segregated Accounts Companies Act Section 17; IRC Section 817(h) and investor-control tests are US rules, not Bermuda rules. Obtain written carrier acceptance for the fund or account.Requires reviewSegregated Accounts Companies Act 2000 Section 17 | No dedicated IDF regime and no minimum premium. Segregation runs through Section 16 linked funds, Section 17 separate accounts, SPC portfolios or PICs. The dataset does not confirm approval of a particular IDF or SMA.Requires reviewInsurance Act 2010 Sections 16, 17; Companies Act Sections 216 to 221 | A dedicated internal fund (FID) needs at least EUR 125,000 at subscription, or EUR 125,000 of firmly committed regular premiums over the first five years, and a category A to D client; it has one manager, one account and one depositary. A specialized insurance fund (FAS) has no premium or wealth condition and follows the client's category limits. Its asset-by-asset selection rights are not a US investor-control safe harbor.Source-supportedCAA Circular 26/1 Sections 7.3.1 to 7.3.5 and 7.4 |
| Currency considerationsDifferent legal or commercial objects | Obtain the actual policy denomination, permitted currencies, valuation method and conversion charges. This dataset does not establish which foreign-currency contracts a particular insurer may issue.Requires reviewContract and form-approval review | Insurance Account Rules 2016 rule 13 fixes only the presentation currency of statutory returns, not the denominations a policy may use. The Bermuda dollar is pegged at par to the US dollar and exempted insurers' policies are commonly in USD, per a law-firm summary (Conyers). The policy currency is agreed with the insurer; confirm it in the policy terms.Requires reviewInsurance Account Rules 2016 rule 13 | CIMA Rule Section 6.2.1 requires attention to the timing, amount and currency of asset and liability cash flows; it is not a rule on policy denomination. The Cayman dollar is pegged to the US dollar (CIMA converts fees at US$ = CI$ / 0.82), policies are usually in USD and there is no exchange control, and the policy currency is agreed with the insurer; confirm it in the policy terms.Requires reviewCIMA Investment Activities Rule Section 6.2.1 | Neither the 2015 law nor Circular 26/1 restricts the policy or fund currency; CAA rules address currency matching of commitments and the reporting currency. Insurers commonly offer EUR, USD, CHF and GBP. The actual denomination and currency options require the contract.Requires reviewRCAA 15/03; contract-specific review |
| Custody considerations | Regulation 1205 Section 6.0: where the insurer does not hold separate-account assets itself, custody contracts must be in writing and the Commissioner may review and approve the terms and the custodian. Staff with access to the assets must be bonded, from US$10,000 for accounts under US$100,000 to US$5,000,000 for accounts over US$1.07 billion. No local custodian or tripartite agreement is required.Source-supported18 Del. Admin. Code 1205-6.0 | No statutory custodian or tripartite custody agreement is prescribed. The Code of Conduct addresses the selection and oversight of custody and investment-management providers; long-term receipts must go into the long-term business fund. The actual safekeeping, cash and insolvency terms require the issuer documents. Custody arrangements are set by the insurer, so confirm them in writing.Requires reviewInsurance Code of Conduct Section 5.1.2; Insurance Act 1978 Section 24 | No custodian is prescribed. The Rule requires assets to be held where no sanctions are breached (6.1.4), and linked assets must be identifiable in segregated funds (Section 16). Obtain the actual custody contract.Requires reviewCIMA Investment Activities Rule 6.1.4; Insurance Act Section 16 | Assets covering technical provisions are deposited with an EEA credit institution under a tripartite agreement between insurer, bank and CAA: segregated, no set-off, no charge other than the Article 118 privilege, and blocked without delay on CAA notice. Since February 1, 2026 (Circular 26/2) a non-EEA depositary is possible only for category A to D clients and FID, FAS or type A to D FIC assets, with the depositary risk borne by the policyholder, a signed declaration, and a depositary country that has completed Basel III.Source-supportedLaw of 7 December 2015 Article 117(2); CAA Circular 16/9 as amended by 26/2 |
| Premium-tax considerations | Section 702(c)(1): 1.75% of net premiums. Section 702(c)(2), per case for employer-owned and trust-owned life: 2.0% on the first US$10,000,000, 1.5% from US$10,000,001 to US$24,999,999, 1.25% from US$25,000,000 to US$99,999,999 and 1.0% from US$100,000,000; in later calendar years the rate may not exceed the preceding year's rate. Section 702(c)(3): 2% on the first US$100,000 of net premium and 0% above it, per policy per year, for trust-owned policies on one life placed privately under federal securities laws, so at most US$2,000. The tax applies to Delaware-located risks, not by insurer domicile.Source-supported18 Del. C. Section 702(a), (c)(1) to (c)(3) | No premium tax applies to business written for non-residents. The 3.5% Financial Services Tax, in force since April 1, 2019, applies only to domestic insurers on gross premiums written each quarter, excluding health insurance, annuities and government insurance; an insurer writing only non-Bermuda business pays none. A policy on the life of a person ordinarily resident outside Bermuda is an exempt policy for stamp duty.Source-supportedFinancial Services Tax Act 2017 Sections 3, 4(b); Stamp Duties Act 1976 Section 1 | The Cayman Islands levy no premium tax, income tax, capital gains tax or corporate tax. No Cayman policy stamp duty is calculated here; ask the insurer whether any is due on the policy documents; PwC lists stamp duty only on land (7.5%), mortgages (1% to 1.5%) and nominal documentary duty capped at CI$500.Requires reviewPwC Worldwide Tax Summaries, May 29, 2026 | Luxembourg charges no premium tax on life insurance: the insurance tax of 3% to 6% applies to all branches except life. Premium taxes of the policyholder's country of residence are separate, for example Swiss stamp duty of 2.5% on a single-premium redeemable policy of a Swiss resident, owed by the policyholder where the insurer is foreign.Source-supportedGuichet.lu, insurance taxes; Swiss StG Articles 21, 22, 24, 25 |
| Structural cost considerations | If Section 702(c)(3) applies to US$25,000,000 of net premium on one policy in one calendar year: 2% of US$100,000 = US$2,000, or 0.8 basis points. Each later year with premium above US$100,000 again costs US$2,000. Other state taxes and all policy charges are excluded.Modeled: stated assumptionsConditional arithmetic under Section 702(c)(3) | BMA fees are insurer-level; the 2025 schedule is shown. Non-domestic Class C annual fees run from US$40,000 (assets up to US$50 million) to US$344,000 above US$5 billion plus 0.001% of the excess; Class D and E from US$216,000 to US$344,000 plus 0.001%. The tool does not allocate them to a policy.Requires reviewBMA 2025 fee schedule, effective Jan. 1, 2025 | CIMA fees from January 1, 2026: application CI$1,000; annual fee (equal to the grant fee) Class B(i) CI$10,450, B(ii) CI$11,550, B(iii) CI$14,850, Class A CI$84,000, Class C CI$6,500, Class D CI$120,000; CI$1,000 per segregated portfolio per year. US$ equals CI$ divided by 0.82, so B(iii) is about US$18,110. Late payment adds one twelfth of the annual fee per month. These are insurer-level fees, not policy charges.Source-supportedInsurance (Applications and Fees) Regulations (2026 Revision); Amendment Regulations 2025 | The CAA annual tax is insurer-level, set on prior-year gross written premiums: EUR 16,000 up to EUR 5 million, EUR 24,000 to EUR 25 million, EUR 32,000 to EUR 75 million, EUR 40,000 to EUR 150 million, EUR 48,000 to EUR 250 million, plus EUR 8,000 per further EUR 250 million tranche or part. Where technical provisions exceed ten times premiums, one tenth of provisions replaces premiums; the minimum is 0.008% of premiums. There is no per-policy regulator fee.Source-supportedRGD of 28 April 2014, Article 2 |
| Policy-loan considerations | Section 2932(e) disapplies Sections 2906 (grace period), 2911 (statutory policy loan), 2912, 2913, 2929 and 3113 to variable life, so PPLI loan terms are contractual. Federal tax: a loan from a non-MEC is not a distribution under Section 72(e); a loan from a MEC is taxed as a distribution.Source-supported18 Del. C. Sections 2911 and 2932(e); IRC Section 72(e) | Life Insurance Act 1978 Section 4(2): the policy must state any options to surrender for cash, obtain a loan or advance, or take paid-up or extended cover. The Act sets no cap, rate or limit on loans, and Section 4 does not apply to group, creditor's group or fraternal contracts. Check whether the Act governs the contract at all.Source-supportedLife Insurance Act 1978 Sections 2 and 4 | The Insurance Act contains no policy-loan provision; loans and advances are contractual. Obtain the policy's loan, collateral and repayment terms.Requires reviewInsurance Act 2010 | Law of 27 July 1997: the right to an advance belongs to the policyholder alone, not to a spouse or creditors, and needs the beneficiary's consent after acceptance (Article 115). A pledge requires a rider signed by policyholder, pledgee and insurer (Articles 116, 117), and a third-party insured must consent in writing (Article 60). No statutory loan-to-value cap exists.Source-supportedLaw of 27 July 1997, Articles 60 and 114 to 117 |
| Asset-protection framework | Section 2932(a)(5): the separate-account portion equal to reserves and other contract liabilities is not chargeable with liabilities of the insurer's other business; surplus above it is not insulated. The Delaware guaranty association covers up to US$300,000 of death benefit and US$100,000 of cash surrender value (US$300,000 per life in total) but excludes the portion where the owner bears the investment risk (Section 4403(b)(2)a).Source-supported18 Del. C. Sections 2932(a)(5), 4403(b)(2)a and (c)(2) | No compensation scheme exists. Long-term receipts are ring-fenced in the long-term business fund (Insurance Act Section 24). A liability linked to a segregated account is a liability only of that account, and its assets are held for the account owners (SAC Act Section 17), subject to documented apportionment (Section 12), counterparty disclosure (Section 9) and inter-account transactions (Section 17A). Once payable, proceeds with a designated beneficiary are outside the insured's estate and creditors (Life Insurance Act Section 25).Source-supportedSAC Act 2000 Sections 9, 12, 17, 17A; Insurance Act 1978 Section 24; Life Insurance Act Section 25 | No compensation scheme exists. Linked policies need segregated funds (Insurance Act Section 16); separate-account assets are kept independent and "shall not be chargeable with any liability arising from any other business" (Section 17). Long-term proceeds are protected from the policyholder's creditors, except premiums paid to defraud, recoverable with interest within 6 years (Section 29). SPC portfolio assets are not available for other portfolios or the general account; recourse to general assets arises only on a portfolio shortfall (Companies Act Sections 219 to 221).Source-supportedInsurance Act 2010 Sections 16, 17, 29; Companies Act (2026 Revision) Sections 219 to 221 | Article 118: assets covering technical provisions form a distinct estate subject to a privilege that ranks ahead of all others once entered on the permanent inventory; Article 119 adds a privileged claim for any shortfall. In a winding-up, unit-linked creditors hold a first-rank privilege on the proceeds of their units, reduced pro rata if units are short, and units may be transferred in kind (Article 253-5). There is no life compensation scheme; the privilege is a claim, not personal title, and is worth what the cover assets are worth.Source-supportedLaw of 7 December 2015, Articles 117 to 121, 253-5 |
| Cross-border considerationsDifferent legal or commercial objects | Section 1905(a): life and health insurance "shall not be considered surplus lines insurance" and must be placed with admitted insurers; surplus lines, taxed at 3% under Section 1925(b), is limited to property and casualty. A non-US carrier cannot write Delaware PPLI through surplus lines. Confirm state authority, solicitation and delivery before a transaction or move.Source-supported18 Del. C. Sections 1904(a)(15), 1905(a), 1925(b) | Bermuda has no passport. Business in or from Bermuda needs registration, and selling abroad depends on the destination country's rules for non-admitted insurers. EU Solvency II equivalence (Delegated Regulation 2016/309) gives no right to solicit EU residents.Requires reviewInsurance Act 1978 Section 3; Delegated Regulation (EU) 2016/309 | No passport. Class B writes non-domestic business and Class A is needed for Cayman domestic business; a branch or office abroad needs CIMA's prior written approval (Section 8(1)(b)). Solicitation in the client's country is governed by that country's law.Requires reviewInsurance Act 2010 Sections 4(3), 8(1)(b) | EU freedom of services: the insurer notifies the CAA in advance (Article 139), and the CAA sends the host state a solvency certificate within one month (Article 140); branches follow Articles 132 to 134. The policyholder's country still applies its general-good rules and taxes. There is no life passport into Switzerland.Source-supportedLaw of 7 December 2015, Articles 132 to 140; Directive 2009/138/EC Articles 145 to 152 |
| US-taxpayer relevance | A policy issued by a Delaware or other US insurer is outside the IRC Section 4371(2) excise, which reaches only foreign insurers. The contract must still satisfy Section 7702 (2% minimum rate for the cash value accumulation test and 4% for guideline single premiums, for contracts issued since 2021) and the Section 817(h) diversification tests.Source-supportedIRC Sections 4371(2), 7702(b), (c), (f)(11), 817(h) | Premiums to a Bermuda insurer on a US insured life bear the IRC Section 4371(2) excise of 1 cent per dollar or fraction. Bermuda treaty relief was overridden for periods after December 31, 1989 and Bermuda is not on the IRS treaty list, so only a valid Section 953(d) election removes the charge. Rev. Proc. 2003-47 then requires a letter of credit of 10% of gross income, from US$75,000 to US$10,000,000, unless the office and asset tests are met.Source-supportedIRC Sections 4371(2), 4372(e), 953(d); Rev. Proc. 2003-47; P.L. 100-647 Section 6139 | There is no US income tax treaty, so no treaty relief: premiums on a US insured life bear the IRC Section 4371(2) excise of 1 cent per dollar or fraction unless the insurer is a CFC with a valid Section 953(d) election (letter of credit of 10% of gross income, US$75,000 to US$10,000,000, where the office and asset tests are not met). A non-US owner does not by itself remove the exposure (Section 4372(e)).Source-supportedIRC Sections 4371(2), 4372(e), 953(d); Rev. Proc. 2003-47 | Luxembourg is one of 16 IRS treaty countries for the Section 4371 excise, for direct insurance only, not reinsurance. Relief requires an IRS closing agreement with the insurer (Rev. Proc. 2003-78) and no reinsurance with a non-entitled person. The IRS closing-agreement lists read in September 2026 show no Luxembourg life insurer, so US-connected premiums generally bear the 1% excise under Section 4371(2).Source-supportedIRS Section 4371 treaty guidance (Mar. 22, 2026); Rev. Proc. 2003-78; IRS closing-agreement lists |
| Estate-planning considerationsDifferent legal or commercial objects | The 2026 basic exclusion is US$15,000,000 per person, made permanent by Pub. L. 119-21 and indexed from 2027; the top rate is 40% and the 2026 annual gift exclusion is US$19,000. Proceeds are included where the decedent held incidents of ownership (Section 2042) or transferred them within three years of death (Section 2035), which is why an irrevocable trust usually owns the policy.Source-supportedIRC Sections 2001(c), 2010(c)(3), 2035, 2042; Rev. Proc. 2025-32 | No inheritance tax, but Stamp Duties Act Section 47 charges duty on the affidavit of a deceased's estate (Head 2; per Conyers, 0% below BM$100,000 and 20% above BM$2 million). For a decedent not domiciled in Bermuda, policy money counts only if payable in Bermuda or in Bermuda currency, and securities in an exempted undertaking are excluded. Sections 47 and 48 were read; the Head 2 bands come from Conyers because the online Schedule is truncated, so this field needs review.Requires reviewStamp Duties Act 1976 Sections 47, 48 | The Cayman Islands levy no estate, inheritance or gift tax. Exempted companies can obtain a Tax Concessions Act undertaking; ask the insurer for its term. The family's and beneficiaries' own countries decide their tax result.Requires reviewPwC Worldwide Tax Summaries; Tax Concessions Act | A non-resident's Luxembourg policy carries no Luxembourg inheritance tax: droits de succession reach estates of residents, and droits de mutation par décès only Luxembourg real estate of non-residents. For residents, the direct line within the legal share, spouses and partners registered for more than three years are exempt; other base rates run from 6% to 15%, with surcharges up to 48% at the top. A Luxembourg resident should take local advice on how life proceeds are treated in the estate.Source-supportedPFI succession pages; Law of 27 December 1817 |
| Reporting considerations | Under FATCA a cash-value insurance contract is a financial account once its cash value exceeds US$50,000 in the calendar year. For foreign policies, Form 8938 applies to a single US-resident filer above US$50,000 at year end or US$75,000 at any time (US$200,000 or US$300,000 if living abroad), and FBAR applies when foreign accounts exceed US$10,000 in aggregate. A foreign trust owner can add Forms 3520 and 3520-A.Source-supportedTreas. Reg. 1.1471-5(b)(3)(vii); IRC Section 6038D; 31 USC 5314 | FATCA Model 2 IGA signed December 19, 2013, with direct reporting to the IRS. CRS runs under the 2017 regulations: the report is due May 31 and the compliance form September 30 through the Bermuda Tax Information Reporting Portal. CITA has been the competent authority since March 13, 2026, and Bermuda is committed to first CARF exchanges by 2027.Source-supportedUS-Bermuda IGA; CRS Regulations 2017 | FATCA under a Model 1B IGA, with reports due July 31. The amended CRS and CARF apply from January 1, 2026, with first reports for 2026 due June 30, 2027; the CRS deadline moves to June 30, registration is due January 31, and continuing penalties are capped at CI$50,000.Source-supportedTIA CRS Amendment Regulations 2025; DITC amended CRS quick guide | FATCA Model 1 IGA signed March 28, 2014 (Law of July 24, 2015); CRS under the Law of December 18, 2015. Reports to the ACD are due June 30. The Law of March 27, 2026 (CRS 2.0 and DAC8) applies from January 1, 2026, with first reports under the new rules due June 30, 2027. Insurers issuing cash-value or unit-linked contracts are reporting financial institutions.Source-supportedLaw of 24 July 2015; Law of 18 December 2015; Law of 27 March 2026 |
| Carrier ecosystemDifferent legal or commercial objects | NAIC Key Facts 2025 (2024 data): 149 domestic insurers of all types in Delaware, and US$118.2 billion of life, accident and health premium written in Delaware, second nationally at 8.50% of the US total. A licensee lookup does not establish a PPLI offer, minimum premium or asset acceptance.Requires reviewNAIC State Insurance Regulation: Key Facts and Market Trends 2025, Delaware | Appleby counted 144 registered long-term insurers and reinsurers in June 2022; the whole market had over 1,200 insurers in October 2025. No current count for Classes C, D and E was confirmed, and most long-term registrants are reinsurers or captives rather than PPLI issuers. Check the issuer on the BMA register.Requires reviewAppleby, June 2022; Chambers 2026; BMA register | CIMA, Q2 2026: 744 licensed insurers (Class A 23; Class B 693, including 137 SPCs, split B(i) 473, B(ii) 14, B(iii) 206; Class C 17; Class D 11), 67 PICs and 629 segregated portfolios. By primary line, 43 international insurers write life business and 7 deferred variable annuities. A licence count is not a count of PPLI issuers.Source-supportedCIMA Insurance Statistics, Q2 2026 | 28 Luxembourg-law life insurers at end 2025 and at July 1, 2026 (29 at end 2024, 30 at end 2023), plus 2 life branches of foreign insurers, within 283 undertakings in total. The register does not identify PPLI writers or their acceptance criteria.Source-supportedCAA annual report 2025/2026, annex Table 2.1 |
| Market dataDifferent legal or commercial objects | No official US PPLI market statistic exists. The February 2024 Senate Finance Committee staff report was reported to find PPLI sheltering up to US$40 billion; the committee no longer hosts the report online. Broad life-insurance statistics measure a different population.Requires reviewSenate Finance Committee staff report, Feb. 2024 (secondary) | Commercial long-term insurers held US$1,274.6 billion of total assets at year-end 2023 and wrote US$169.8 billion of gross premiums (BMA, December 2024). Later figures (long-term gross written premium up 17.8% to US$200.1 billion; whole market above US$1.6 trillion of assets in October 2025) come from industry reports rather than BMA publications. None of these figures measures PPLI.Source-supportedBMA Long-term Insurance Market Analysis and Stress Testing Report, December 2024 | International insurers at June 30, 2026: 721 (Classes B, C and D), with total premiums of US$61.36 billion and total assets of US$189.63 billion; Class B alone US$53.4 billion of premiums and US$159.9 billion of assets. These totals span captives and reinsurance and are not a PPLI market size.Source-supportedCIMA Insurance Statistics, Q2 2026 | Life premiums of Luxembourg insurers: EUR 31.13 billion in 2025 (+16.17%), 73% unit-linked, per CAA quarterly indicators; the annual report's broader scope gives EUR 35 billion (+18.9%). First half 2026: EUR 17.43 billion (+10.93%), of which unit-linked EUR 12.43 billion (71.3%). Life technical provisions reached EUR 279.42 billion at June 30, 2026 (+13.51%), 80.8% unit-linked. These are not PPLI-only figures.Source-supportedCAA quarterly indicators 2025 Q4 and 2026 Q2; press release, Aug. 5, 2026 |
| Pending change | S. 4279, the Protecting Proper Life Insurance from Abuse Act, introduced April 13, 2026, would add Section 7702C denying life-insurance treatment to applicable private placement contracts, with a 180-day window for existing contracts; it is not enacted. Press reports say the Section 7702 rates rise to 3% and 5% on January 1, 2028; confirm this against the enacted text. Delaware's 2025 amendment (85 Del. Laws c. 7) changed only the estimated-payment dates.Requires reviewS. 4279 (119th Congress); 85 Del. Laws c. 7 | Recent changes: prudent person guidance (July 1, 2025); Tax Credits Act 2025, with the credit phased at 50% for 2025, 75% for 2026 and 100% from 2027; asset and liability statements for Classes C, D and E (January 1, 2026); Insurance Amendment (No. 2) Act 2025 (January 7, 2026); CITA as CRS authority (March 13, 2026). Corporate income tax at 15% applies only to groups with revenue of EUR 750 million or more. Planned: conduct rules for international retail business.Source-supportedInsurance Amendment (No. 2) Act 2025; Tax Credits Act 2025; Corporate Income Tax Act 2023 | January 1, 2025: Insurance (Amendment and Validation) Act 2024. January 1, 2026: amended CRS and CARF, a new CIMA fee schedule raising Class B fees by 10%, and the Companies Act 2026 Revision. January 1, 2027: CIMA regulatory policy on approval of auditors.Source-supportedCIMA regulatory measures; SL 56 of 2024 | Circulars 26/1 and 26/2 took effect February 1, 2026, with prior rules preserved for existing contracts and funds (26/1 Section 10). CRS 2.0 and DAC8 apply from January 1, 2026. The Solvency II review (Directive (EU) 2025/2) and the insurance recovery and resolution directive (2025/1) are due to apply from January 30, 2027; check the status of the Luxembourg implementing bill.Source-supportedCAA Circulars 26/1 Section 10, 26/2; Law of 27 March 2026 |
| Key limitations | Section 702(c)(3) does not reach individually owned or entity-owned policies, and probably not survivorship policies, which fall under the 1.75% rate or the per-case bands. The guaranty association excludes separate-account values, loan rights are contractual, and investment permissions and tax allocation need issuer-specific review.Requires reviewCountry research and the source-linked fields above | No compensation scheme, no passport and no statutory IDF regime; the 1% US excise applies unless the insurer has made a Section 953(d) election; and much of the long-term market is reinsurance or asset-intensive business rather than private placement.Requires reviewCountry research and the source-linked fields above | No compensation scheme, no treaty network and no passport; the 1% US excise applies absent a Section 953(d) election; the Class B(iii) long-term capital floor is only US$400,000, so check the carrier's actual capital; and ask whether stamp duty is due on the policy documents.Requires reviewCountry research and the source-linked fields above | No life compensation scheme; FID access needs EUR 125,000 and category A or above; non-EEA custody only for categories A to D with the policyholder bearing depositary risk; no Luxembourg life insurer on the IRS closing-agreement lists; and residence-country premium taxes still apply.Requires reviewCountry research and the source-linked fields above |
| Where it may be less appropriate | Clients with no US nexus; policies that are not trust-owned single-life private placements, which lose the US$2,000 cap; and buyers who need a statutory custody regime or a non-USD policy whose form approval is uncertain.Requires reviewCountry research and the source-linked fields above | EU residents, since there is no freedom of services; clients who want a statutory super-privilege or a tripartite custody model; and clients who want investment limits fixed by law.Requires reviewCountry research and the source-linked fields above | EU and UK residents, since the insurer is non-EEA and unauthorized there; clients who need statutory investment limits or a tripartite custody model; and clients who need a documented stamp-duty position on the policy.Requires reviewCountry research and the source-linked fields above | US persons, because of the 1% excise without a closing agreement and no verified Luxembourg Section 953(d) election; clients below EUR 125,000 or unable to show EUR 250,000 of securities wealth who want a dedicated fund; and holders of illiquid or non-financial assets, which category D excludes.Requires reviewCountry research and the source-linked fields above |
Market figures can describe all life insurance, international insurers or technical commitments. They do not describe the same population. Registry entries do not establish which products are currently offered. Policy denomination is separate from statutory reporting currency and asset/liability matching.
Beyond the comparison table
Liechtenstein, Ireland and Singapore are ranked in the selector; Switzerland stays as linked research.
The table above has four columns. The selector also ranks Liechtenstein, Ireland and Singapore, scored from sources checked on the same date, September 24, 2026. Switzerland is not ranked as a domicile, although its stamp duty and authorization rules apply to Swiss residents in every result. Ireland has no separate research profile yet; its selector row links to the Central Bank of Ireland insurance data. Each summary below lists what the check documents and what is still missing for a twenty-field table profile.
Liechtenstein Research profile
FMA supervision under the Insurance Supervision Act (VersAG, LGBl. 2015 Nr. 231); an EEA passport (VersAG Article 17(5)) plus a direct-insurance treaty with Switzerland; in insolvency, cover assets form a special estate whose insurance claims rank ahead of all other claims (VersAG Articles 161 and 161a); Swiss stamp duty of 2.5% on single-premium redeemable policies of Swiss or Liechtenstein residents only; no US treaty, so the 1% excise applies unless the insurer made a Section 953(d) election. FMA 2025 figures: 30 insurers, gross premiums CHF 4.90 billion of which life CHF 2.50 billion, and CHF 19.8 billion held for policyholders' account and risk.
- The FMA may restrict unit-linked assets for natural persons under VersAG Article 81(4); ask the insurer for its asset policy
- No statutory IDF regime or minimum; dedicated-mandate minimums are set by each insurer
- No statutory policy-loan provision; loans depend on the policy terms
- The FMA register lists 26 life entries against 30 insurers in FMA reports
Singapore Research profile
MAS licensing under the Insurance Act 1966 with separate funds for Singapore and offshore policies; the SDIC Policy Owners' Protection Scheme covers guaranteed benefits up to S$500,000 sum assured and S$100,000 surrender value per life per insurer, including offshore policies, but not non-guaranteed investment-linked values; no premium tax, GST exemption for life premiums and no estate duty since February 15, 2008; no US treaty, so the 1% excise applies unless the insurer made a Section 953(d) election. LIA 2025: weighted new business premiums S$6.53 billion (+11.3%), investment-linked S$2.88 billion.
- MAS Notice 307 text: whether single-policyholder dedicated sub-funds or accredited-investor exemptions are permitted
- The number of licensed life insurers (see the MAS Financial Institutions Directory)
- Trust-nomination rules (Insurance Act Sections 132 and 133): confirm the current text
- First-half 2026 LIA figures, to be confirmed against the LIA release
Switzerland Research profile
FINMA supervision under the VAG and AVO as revised on January 1, 2024; policyholder claims secured by tied assets and ranked under VAG Article 54a; federal stamp duty of 2.5% on single-premium redeemable life policies of Swiss residents, with periodic premiums and policyholders domiciled abroad exempt; US treaty relief from the 1% excise with an IRS closing agreement; no EU passport for life. FINMA 2025: 19 life insurers, life premiums CHF 24.53 billion, unit-linked premiums CHF 2.26 billion and unit-linked investments CHF 29.92 billion.
- The ESTV practice on asset-management insurance for Swiss residents
- FINMA supervisory fees
- Statutory policy-loan rules (none verified)
- Cantonal inheritance-tax detail
Methodology
What each answer changes, how each criterion is scored and how the ranking is built.
What the selector evaluates
Seven insurer domiciles: the United States (Delaware), Luxembourg, Liechtenstein, Ireland, Bermuda, the Cayman Islands and Singapore. Each is scored from 0 to 10 on eight criteria: tax and entry cost, insurer protection, investment flexibility, estate and succession, privacy and reporting, portability, regulatory strength and administrative simplicity. Every score comes from a statute, regulator or tax-authority source checked on September 24, 2026, and is recorded in the published data file with its reason, citation and evidence state. Where the law leaves a point to the insurer or to market practice, the score is set cautiously and marked beside the figure. Some scores depend on your answers, for example the Luxembourg investor category, US-person status or the owner.
What it does not evaluate
It does not underwrite an insured life, confirm a carrier offer or its charges, approve investments, test a particular contract under Section 7702, or project returns. A domicile score describes the legal framework, not a named insurer. The US profile is a Delaware framework, not a fifty-state survey.
The ten questions
Residence, US-person status, owner, premium, payment pattern, declared securities wealth, assets, policy currency, priorities and relocation. Every question has a default, so a result is always computed. Closed premium bands use their midpoint and the top band uses US$100 million; an exact amount replaces the band. Payment over 2 to 5 years is modeled as five equal annual premiums and over more than 5 years as ten. Declared wealth is used only for the Luxembourg category and, if left at the default, is taken to equal the premium.
How each criterion is scored
- Tax and entry cost: 10 minus 2.5 points for each 1% of the premium taken by entry taxes computed on your amount, then residence rules that differ by domicile (Portugal's 35% rate for listed jurisdictions, France's lost allowance outside the EEA, the unsettled Spanish deferral for non-EEA insurers).
- Insurer protection: 10 would need segregated assets in independent custody, a first-rank privilege and a payout scheme behind them; no domicile here has all three. 9 for segregated cover assets with a first-rank privilege and bank custody but no compensation scheme (Luxembourg); 8 for a statutory special estate or an insulated separate account (Liechtenstein, Delaware); 7 for segregated funds or accounts with no compensation scheme (Bermuda, Cayman Islands); 6 where policyholders rely on a winding-up priority (Ireland, Singapore). The same scale is used in the UK edition, where the Isle of Man also scores 9.
- Investment flexibility: the domicile's asset rules for your tier and asset type, with Luxembourg scored from the LC 26/1 category your premium and declared wealth reach. For a US taxpayer every domicile is capped at 6 by Section 817(h) diversification and investor control.
- Estate and succession: death duties the domicile could levy on a non-resident's policy and statutory beneficiary protection. For a US person the federal estate tax applies wherever the policy is issued, so the score is equal.
- Privacy and reporting: a statutory insurer-secrecy rule scores higher. CRS reporting applies in every domicile outside the US and is stated in every result.
- Portability: the EEA passport, marketing rules for your residence and, for US persons, onshore placement.
- Regulatory strength: codified regime, supervisor and market depth.
- Administrative simplicity: the filings that fall on you, such as FBAR, Form 8938, Form 720 or self-assessed residence taxes.
Weights
Without priorities the selector uses default weights for your residence group (United States, Europe, international, Asia, Latin America), shown with every result. Choosing priorities sets your first to 3, the second to 2 and the third to 1.5, and every other criterion to 1. A yes to relocation raises the portability weight to at least 2 (not sure: at least 1.5), even if you ranked portability lower among your priorities. The match score is the weighted average times ten; ties go to insurer protection, then tax and entry cost, then regulatory strength.
Constraints
Hard constraints change criterion scores and are listed with their reasons: EU freedom of services (Bermuda, Cayman Islands, Singapore and a US carrier capped on portability for EEA residents), UK promotion rules, Swiss authorization and the CH-FL agreement, Delaware for a family with no US connection, Portugal's 35% rate, and residence rules that apply equally to every domicile (India's RBI permission, China's foreign exchange quota, Mexican and Brazilian purchase rules). None excludes a domicile.
Sources, conflicts and dates
Use the cited statute or regulator document within its scope, together with later amendments and actual issuer documents. A regulator register answers an authorization question; it does not establish a policy's charges. Where sources concern different objects or cannot settle the specific issue, the field requires review. Check the linked current instrument before relying on a historical revision.
The editorial date records this dataset check, not independent professional approval or a promise of automatic updates. Dataset, methodology and engine versions are shown separately. The date does not imply continuous monitoring of legal changes.
The formulas
Reproduce source coverage and the selected tax components.
Let P be the premium used by the selector: the band midpoint, or the exact amount you enter. An invalid exact amount is not accepted and the band is kept, so every figure is computed.
Match score
round(10 × Σ(wc × sc) ÷ Σ wc) over the eight criteria c, where sc is the criterion score from 0 to 10 and wc its weight. Ties: insurer protection, then tax and entry cost, then regulatory strength.
Tax and entry cost score
max(0, 10 − 2.5 × E ÷ P × 100), where E is the sum of the entry taxes computed below for that domicile, then the residence adjustments listed with the result.
Luxembourg investor category (LC 26/1, point 2)
D if premium ≥ EUR 1,000,000 and declared securities wealth ≥ EUR 2,500,000; C if ≥ EUR 250,000 and ≥ EUR 1,250,000; B if ≥ EUR 250,000 and ≥ EUR 500,000; A if ≥ EUR 125,000 and ≥ EUR 250,000; otherwise N. Both conditions must be met.
Swiss stamp duty
0.025 × P on a single premium paid by a Swiss resident, whatever the domicile (StG Art. 24); nil on periodic premiums that meet StV Art. 26b.
Currency
Amounts shown in EUR, GBP or CHF are converted from US dollars at the ECB euro reference rates of September 24, 2026: EUR 1 = US$1.1367 = GBP 0.85986 = CHF 0.9409.
Delaware general schedule
P × 0.0175, assuming Section 702(c)(1) applies.
Delaware first-year per-case schedule
0.02 × min(P, 10,000,000)
+ 0.015 × min(max(P − 10,000,000, 0), 15,000,000)
+ 0.0125 × min(max(P − 25,000,000, 0), 75,000,000)
+ 0.01 × max(P − 100,000,000, 0).
Section 702(c)(2), per case per calendar year. In later years the rate may not exceed the preceding year's rate.
Delaware qualifying private placement
0.02 × min(P, 100,000), assuming Section 702(c)(3) applies to that policy and calendar year. The maximum is US$2,000 per policy per year.
Selected foreign-life excise scenario
0.01 × ceiling(P), where ceiling rounds up to the next whole dollar (IRC Section 4371(2): 1 cent per dollar or fractional part). Per premium payment. It applies where the insured is a US person (Section 4372(e)); a valid Section 953(d) election, or treaty relief with an IRS closing agreement, reduces it to zero. The selector shows these conditions beside the figure.
All amounts are rounded to whole cents. Section 4373 includes possible exemptions, including qualifying effectively connected income. A valid Section 953(d) election is not the only possible route; where the office and asset tests are not met, Rev. Proc. 2003-47 requires a letter of credit of 10% of gross income, at least US$75,000 and at most US$10,000,000. Voluntary revocation requires Commissioner consent under the procedure. The tool does not independently establish any exemption.
Sources and research links
Statutes, regulators, tax authorities and explicitly identified research references.
Each table cell links to its specific citation. The list below deduplicates those destinations. A reference in a field marked requires review is a research starting point, not evidence that the unresolved proposition has been established. The editorial-check date is September 24, 2026.
- Delaware Department of Insurance
DOI 2025 data release, Feb. 2, 2026. United States. - Delaware Code Online
18 Del. C. Sections 702, 2932, 1905, 4403; 80 Del. Laws c. 222; 18 Del. C. Section 2932(a)(1), (2), (4); 18 Del. Admin. Code 1205-6.0; 18 Del. C. Sections 2911 and 2932(e); IRC Section 72(e). United States. - Delaware Department of Insurance
Issuer-specific authorization review. United States. - eCFR; IRS
Treasury Regulation 1.817-5(b), (c), (f). United States. - Delaware Code Online
Contract and form-approval review. United States. - Delaware Administrative Code
18 Del. Admin. Code 1205-6.0. United States. - Delaware Code Online
18 Del. C. Section 702(a), (c)(1) to (c)(3); Conditional arithmetic under Section 702(c)(3). United States. - Delaware Code Online
18 Del. C. Sections 2932(a)(5), 4403(b)(2)a and (c)(2). United States. - Delaware Code Online
18 Del. C. Sections 1904(a)(15), 1905(a), 1925(b). United States. - US Code
IRC Sections 4371(2), 7702(b), (c), (f)(11), 817(h); IRC Sections 4371(2), 4372(e), 953(d); Rev. Proc. 2003-47. United States, Cayman Islands. - IRS; US Code
IRC Sections 2001(c), 2010(c)(3), 2035, 2042; Rev. Proc. 2025-32. United States. - IRS
Treas. Reg. 1.1471-5(b)(3)(vii); IRC Section 6038D; 31 USC 5314. United States. - NAIC
NAIC State Insurance Regulation: Key Facts and Market Trends 2025, Delaware. United States. - PPLI.com research
Senate Finance Committee staff report, Feb. 2024 (secondary). United States. - GovInfo
S. 4279 (119th Congress); 85 Del. Laws c. 7. United States. - PPLI.com research
Country research and the source-linked fields above. United States. - Bermuda Laws
Insurance Act 1978; Economic Substance Amendment Act 2026; Insurance Act 1978 (2025:33); Life Insurance Act 1978; SAC Act 2000; Insurance Act 1978 Sections 4EB to 4EF, 4EJ. Bermuda. - Bermuda Monetary Authority
Insurance Code of Conduct; BMA prudent person guidance, July 1, 2025; Insurance Code of Conduct Section 5.1.2; Insurance Act 1978 Section 24. Bermuda. - Bermuda Laws
Segregated Accounts Companies Act 2000 Section 17; SAC Act 2000 Sections 9, 12, 17, 17A; Insurance Act 1978 Section 24; Life Insurance Act Section 25. Bermuda. - Bermuda Monetary Authority
Insurance Account Rules 2016 rule 13. Bermuda. - Bermuda Laws
Financial Services Tax Act 2017 Sections 3, 4(b); Stamp Duties Act 1976 Section 1. Bermuda. - Bermuda Monetary Authority
BMA 2025 fee schedule, effective Jan. 1, 2025. Bermuda. - Bermuda Laws
Life Insurance Act 1978 Sections 2 and 4. Bermuda. - Chambers Insurance and Reinsurance 2026
Insurance Act 1978 Section 3; Delegated Regulation (EU) 2016/309. Bermuda. - IRS
IRC Sections 4371(2), 4372(e), 953(d); Rev. Proc. 2003-47; P.L. 100-647 Section 6139; IRS Section 4371 treaty guidance (Mar. 22, 2026); Rev. Proc. 2003-78; IRS closing-agreement lists. Bermuda, Luxembourg. - Bermuda Laws
Stamp Duties Act 1976 Sections 47, 48. Bermuda. - Corporate Income Tax Agency
US-Bermuda IGA; CRS Regulations 2017. Bermuda. - Bermuda Monetary Authority
Appleby, June 2022; Chambers 2026; BMA register. Bermuda. - Bermuda Monetary Authority
BMA Long-term Insurance Market Analysis and Stress Testing Report, December 2024. Bermuda. - Government of Bermuda; BMA
Insurance Amendment (No. 2) Act 2025; Tax Credits Act 2025; Corporate Income Tax Act 2023. Bermuda. - PPLI.com research
Country research and the source-linked fields above. Bermuda. - CIMA
Insurance Act 2010; Monetary Authority Act. Cayman Islands. - CIMA
Insurance Act 2010; SL 56 of 2024; Companies Act (2026 Revision). Cayman Islands. - CIMA
Insurance Act 2010 Section 4(3); Capital and Solvency (Classes B, C and D) Regulations (2018 Revision); Insurance Act 2010 Sections 16, 17; Companies Act Sections 216 to 221; Insurance Act 2010; Insurance Act 2010 Sections 4(3), 8(1)(b). Cayman Islands. - CIMA
CIMA Investment Activities Rule 6.1.1, 6.2.5, 6.4.6; Insurance Act Section 16; CIMA Investment Activities Rule Section 6.2.1; CIMA Investment Activities Rule 6.1.4; Insurance Act Section 16. Cayman Islands. - PwC
PwC Worldwide Tax Summaries, May 29, 2026. Cayman Islands. - CIMA
Insurance (Applications and Fees) Regulations (2026 Revision); Amendment Regulations 2025. Cayman Islands. - CIMA; Cayman Islands Legislation
Insurance Act 2010 Sections 16, 17, 29; Companies Act (2026 Revision) Sections 219 to 221. Cayman Islands. - PwC
PwC Worldwide Tax Summaries; Tax Concessions Act. Cayman Islands. - Department for International Tax Cooperation
TIA CRS Amendment Regulations 2025; DITC amended CRS quick guide. Cayman Islands. - CIMA
CIMA Insurance Statistics, Q2 2026. Cayman Islands. - CIMA
CIMA regulatory measures; SL 56 of 2024. Cayman Islands. - PPLI.com research
Country research and the source-linked fields above. Cayman Islands. - Legilux
Law of 7 December 2015, Articles 7, 31, 44; Law of 7 December 2015, Articles 132 to 140; Directive 2009/138/EC Articles 145 to 152. Luxembourg. - Commissariat aux Assurances
Law of 7 December 2015; Law of 27 July 1997; CAA Circulars 26/1, 26/2, 16/9; CAA Circular 26/1 Section 2 and Annex 1; CAA Circular 26/1 Sections 7.3.1 to 7.3.5 and 7.4; CAA Circulars 26/1 Section 10, 26/2; Law of 27 March 2026. Luxembourg. - Commissariat aux Assurances
Law of 7 December 2015 Article 44 and Annex II; RGD of 28 April 2014 Article 2; Circular 26/1 Section 7.1.2. Luxembourg. - Commissariat aux Assurances
RCAA 15/03; contract-specific review. Luxembourg. - Commissariat aux Assurances
Law of 7 December 2015 Article 117(2); CAA Circular 16/9 as amended by 26/2. Luxembourg. - Guichet.lu; ESTV
Guichet.lu, insurance taxes; Swiss StG Articles 21, 22, 24, 25. Luxembourg. - Commissariat aux Assurances
RGD of 28 April 2014, Article 2. Luxembourg. - Commissariat aux Assurances
Law of 27 July 1997, Articles 60 and 114 to 117. Luxembourg. - Commissariat aux Assurances
Law of 7 December 2015, Articles 117 to 121, 253-5. Luxembourg. - Administration de l'enregistrement (PFI)
PFI succession pages; Law of 27 December 1817. Luxembourg. - Administration des contributions directes
Law of 24 July 2015; Law of 18 December 2015; Law of 27 March 2026. Luxembourg. - Commissariat aux Assurances
CAA annual report 2025/2026, annex Table 2.1. Luxembourg. - Commissariat aux Assurances
CAA quarterly indicators 2025 Q4 and 2026 Q2; press release, Aug. 5, 2026. Luxembourg. - PPLI.com research
Country research and the source-linked fields above. Luxembourg.
Additional federal references: Section 4373 exemptions, Rev. Proc. 2003-47, Section 7702, Section 7702A, Section 817 and S. 4279 as introduced.
Limits of this comparison
Unmodeled charges, country-specific facts and personal information.
- Tax components have different scopes. The domestic example models a selected Delaware schedule. Foreign examples model selected US excise treatment. Local and other-country taxes and all policy charges remain outside the amounts.
- A ranking is not a recommendation. It weighs framework facts for a stated profile. It does not assess a named insurer, its solvency, its charges or its service.
- Policy-specific evidence is essential. Premiums, underwriting, investment acceptance, loans, guarantees, surrender charges and service rights must come from the actual issuing insurer and contract.
- Legal systems can overlap. Review the owner, insured, beneficiary, trust, issuer, assets and each relevant country. A single residence selection cannot reproduce that analysis.
- No anonymous-market estimates. Insurer counts, life-sector assets and technical commitments are not interchangeable measures of PPLI activity.
- Inputs and site measurement. This calculator processes its scenario inputs in the browser. Its optional measurement events contain interaction counts rather than premium values. This statement concerns this tool; other site features and external services have separate handling described in the privacy policy.
- Review before acting. The output is educational research. Obtain qualified insurance, tax and legal review for an actual policy, transaction or move.
Review status and versions
The dated editorial check and the professional review still required.
This version, checked on September 24, 2026, rechecks every field against dated sources from statutes, regulators and tax authorities: Delaware Section 702 schedules, the Section 4371(2) excise, the 2026 US estate exclusion of US$15,000,000, Bermuda class thresholds and Financial Services Tax scope, 2026 CIMA fees and Q2 2026 statistics, and Luxembourg Circular 26/1 thresholds, 2025 and first-half 2026 market figures and the 28 Luxembourg life insurers. Fields not supported by a primary source keep the Requires review label. No named independent professional has signed off this dataset or calculator. A source-supported statement is limited to its cited framework and does not certify an individual transaction.
Evidence needed for a transaction
- The issuing entity's current authority and complete policy documents.
- Applicable domicile, delivery, tax-residence and insured-life analysis.
- Investment acceptance, diversification and investor-control review.
- Custody agreements, asset allocation, recourse and insolvency analysis.
- Complete policy costs, tax treatment, reporting, succession and servicing terms.
Use the editorial standards to understand the site's approach and the consultation page to ask about PPLI. Neither a calculator result nor an enquiry constitutes insurer acceptance or professional sign-off.
Jurisdiction research
PPLI Jurisdiction Research
Our published research on individual jurisdictions, including those not yet modeled by the engine.
PPLI in California: What a Policy Changes for California Residents
PPLI in Switzerland: Tax Conditions, Stamp Duty and Access
Delaware PPLI: Separate Accounts, Tax and Policy Limits
Liechtenstein PPLI: Insurance Rules, Protection and Suitability
Cayman Islands PPLI: Insurance Structures, Tax and Due Diligence
Singapore PPLI: Tax, Eligibility and Policyholder Protection
Luxembourg PPLI: Policyholder Protection and U.S. Suitability
Bermuda PPLI: Regulation, Tax Conditions and Carrier Selection
Related PPLI research
Where to go next
To model costs, tax drag and structure beyond the choice of jurisdiction, the public analytical tools are collected in Wealth Intelligence; the PPLI Tax-Alpha Simulator remains available for advisers.