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
Explore four jurisdictions, with source links and explicit tax assumptions. No email address is required.
The worked example and full comparison below are available even if the interactive profiles do 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 tool below the introduction uses four research profiles and twenty dimensions. Its source-coverage percentages describe the documentation in this dataset. They are not suitability scores. Tax examples use assumptions you select, with missing information left uncalculated.
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 the portion representing reserves and other contract liabilities. It is not personal ownership of the underlying securities.
- 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.
- 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.
- Luxembourg: examine the asset inventory, deposit agreement and claim priority. The insurance-sector law and CAA custody rules contain conditions and exceptions, including cash-account treatment and winding-up allocation.
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 specialised insurance fund does not settle all three.
Luxembourg Circular 26/1 illustrates the distinction. Its asset categories depend on both premium and securities wealth. A specialised 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 delivery, 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. 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 owner answer alone does not establish these facts. The default US$25 million to US$50 million band uses US$37.5 million; enter US$25 million to reproduce this example.
| 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 | US$0.01 per dollar or fraction 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 | US$0 of the modeled federal excise |
| Tax scope or premium amount unconfirmed | Insufficient inputs | Not determined |
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; later years require the statutory prior-year rule and case aggregation. The private-placement row applies per policy per calendar year when the provision applies.
The foreign rows omit local premium taxes, stamp duties and taxes imposed by other countries. Cayman stamp duty is not a flat US$200 premium charge: the life-policy schedule uses the sum insured and Cayman Islands currency. This tool does not collect those necessary facts.
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, IRS Publication 510, Section 4372, Section 4373, Rev. Proc. 2003-47 and IRS treaty-relief guidance.
How to read a result
Research profiles, source coverage and the meaning of an unknown tax amount.
All four jurisdictions appear alphabetically. Each card is a research profile, with a source-supported field count, missing research priorities, conditional tax arithmetic and a link to the country article. The tool does not select a winner or classify a policy as suitable.
- Source-supported: the cited material supports the limited statement in the field. It does not verify a particular insurer, policy or transaction.
- Modeled: an illustration derived from stated assumptions. It is not an observed price.
- Requires review: issuer-specific, country-specific or additional primary-source evidence remains necessary. A research link is provided where available.
- Outside this dataset: a linked country article exists, but the jurisdiction has no twenty-dimension profile in this engine.
Not determined means the required tax scenario or valid amount is missing. US$0 means a selected assumption produces zero for that component only. It does not mean the policy is free of tax or charges.
The source-coverage count excludes the two derived summary rows, leaving eighteen fields per jurisdiction. The weighted percentage describes coverage of your selected research priorities. Neither percentage measures safety, expected return, legal certainty or the quality of a regulator.
The full comparison: 20 dimensions across four jurisdictions
All eighty fields, with their evidence states and direct 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 supervises Delaware insurance entities. Identify the issuing entity and the states relevant to solicitation and delivery.Source-supportedCompany Regulation Division | The Bermuda Monetary Authority supervises insurance business under the Insurance Act 1978. Check the actual issuing entity and its registration conditions.Source-supportedInsurance Act 1978, as amended | The Cayman Islands Monetary Authority supervises insurers and relevant portfolio insurance companies. Verify the issuing legal entity and its current authority.Source-supportedCIMA insurance supervision and licence FAQs | The Commissariat aux Assurances supervises Luxembourg insurance undertakings. Confirm the issuing entity and its authorised branches.Source-supportedCAA |
| Statutory framework | 18 Del. C. Section 2932 governs the establishment and treatment of separate accounts and variable contracts. State authorisation and policy requirements remain relevant.Source-supported18 Del. C. Section 2932 | The Insurance Act 1978 and applicable BMA rules govern insurers. The Life Insurance Act and any segregated-account legislation have distinct scopes; identify which govern the actual contract.Source-supportedInsurance Act 1978; related contract and account legislation | Use the Insurance Act 2010 with its amendments, applicable CIMA measures and any SPC or PIC legislation. A historic original Act alone is not a complete statement of current requirements.Requires reviewCIMA acts and regulations index | The Law of 7 December 2015, as amended, and applicable CAA instruments govern insurers. Circular 26/1 applies from February 1, 2026, with specific rules for existing arrangements.Source-supportedCAA Circular 26/1 Section 10; insurance-sector law |
| Licence class | Confirm the actual insurer life and variable-contract authority and the distribution permissions for the proposed state. A PPLI label is not evidence of an authorisation.Requires reviewIssuer-specific authorisation review | Long-term registration classes have different criteria. Commercial Classes C, D and E use asset thresholds; that does not make every long-term class a size band or certify a particular PPLI product.Source-supportedInsurance Act 1978 Sections 4EB-4EF | Class A concerns domestic business; Class B concerns business other than domestic business, with statutory conditions and subcategories. Confirm the issuer actual class and any restrictions.Source-supportedCIMA insurance licence FAQs | Authorisation is granted by insurance branch. The life-insurance classes in Annex II include investment-linked life business. An authorised branch does not prove a particular client can buy a policy.Source-supportedInsurance-sector law Annex II |
| Investment architectureDifferent legal or commercial objects | Section 2932(a)(2) relaxes life-insurer investment limits for separate accounts, subject to the guaranteed-benefit provisions. Contract restrictions, federal tax rules and other applicable requirements still need review.Source-supported18 Del. C. Section 2932(a)(2)-(4) | BMA Insurance Code of Conduct Section 5.1.2 addresses prudent investment, concentration, liquidity, valuation and oversight. The insurer must confirm the assets and management arrangements permitted for the policy.Source-supportedInsurance Code of Conduct Section 5.1.2 | CIMA investment rules require appropriate asset/liability matching, including for linked or universal-life benefits, and segregation where required. Insurance Act Sections 16 and 17 address distinct linked-policy and separate-account provisions.Source-supportedCIMA Investment Activities Rule Sections 6.2.5 and 6.3.2; Insurance Act Sections 16-17 | Circular 26/1 categories require both premium and securities-wealth conditions: A EUR125,000/EUR250,000; B EUR250,000/EUR500,000; C EUR250,000/EUR1.25M; D EUR1M/EUR2.5M. N is the default. Asset limits and insurer restrictions remain relevant.Source-supportedCAA Circular 26/1 Sections 2 and 7.3.2 |
| IDF / SMA availabilityDifferent legal or commercial objects | Treasury Regulation 1.817-5(f) permits conditional look-through for specified RICs, REITs, partnerships and grantor trusts. A manager or SMA label is not a separate tax safe harbor.Source-supportedTreasury Regulation 1.817-5(b), (f) | Obtain written carrier acceptance for the proposed fund or managed account. This dataset does not establish a product-specific permission or a US tax conclusion for the arrangement.Requires reviewCarrier investment approval and federal tax review | Review the insurer approved investment policy, fund documents, management mandate and applicable tax tests. The dataset does not confirm approval of a particular IDF or SMA.Requires reviewCIMA Investment Activities Rule Sections 6.3 and 6.4 | Dedicated funds generally require EUR125,000 at subscription, with a conditional regular-premium exception over five years. A specialised insurance fund has different rules and selection rights; those rights are not a US investor-control safe harbor.Source-supportedCAA Circular 26/1 Sections 7.3.1 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 address the presentation currency of statutory returns. A reporting currency is not evidence of the denominations available under a particular policy.Source-supportedInsurance 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. Confirm actual policy denomination and conversion terms separately.Source-supportedCIMA Investment Activities Rule Section 6.2.1 | CAA rules distinguish representation and currency matching of commitments from reporting currency. Actual policy denomination and currency options require the contract.Requires reviewRCAA 15/3; contract-specific review |
| Custody considerations | Delaware variable-life rules address written custody arrangements in specified circumstances. Identify the custodian and the applicable agreements; do not infer the actual safeguards from domicile alone.Requires review18 Del. Admin. Code 1205; issuer custody review | The Code of Conduct addresses selection and compensation of custody and investment-management providers. The actual safekeeping, control, cash and insolvency arrangements require the issuer documents.Source-supportedInsurance Code of Conduct Section 5.1.2 | CIMA investment guidance addresses control of assets held outside the Islands. Determine the actual custody contract and whether any domestic-business trust requirement applies.Requires reviewCIMA Investment Activities guidance; Insurance Act Section 15 | CAA Circular 16/9 provides approved deposit arrangements and blocking mechanisms, with conditions and exceptions, including specified cash-only accounts. Confirm the actual inventory, bank, agreement and any non-EEA depositary risk terms.Source-supportedCAA Circular 16/9, coordinated February 1, 2026 |
| Premium-tax considerations | Section 702 provides a general 1.75% rate, an employer/trust per-case schedule and a qualifying trust-owned single-life private-placement schedule. Delivery, tax allocation and statutory definitions matter; issuer domicile alone is insufficient.Source-supported18 Del. C. Section 702(a)-(c) | Financial Services Tax applies to domestic insurers at 3.5% of relevant gross premiums, subject to statutory exclusions. Review domestic-business definitions, stamp-duty provisions and the actual risks; do not assume every foreign-issued policy is exempt.Source-supportedFinancial Services Tax Act 2017 Sections 2 and 4 | The life-policy stamp schedule uses the sum insured, with CI$25 minimum and CI$200 maximum under its ordinary formula. A conditional CI$100 cap contains specified certification and licence language. Confirm applicability and any subsequent change.Source-supportedStamp Duty Act, 2019 Revision, life-policy schedule | Luxembourg life-branch tax treatment does not establish the taxes due in the owner or commitment country. Determine the applicable premium or stamp duty and exemptions for the actual policy.Requires reviewCross-border premium-tax and stamp-duty review |
| Structural cost considerations | If Section 702(c)(3) applies to US$25M of taxable net premiums for one policy in one calendar year, the arithmetic is US$2,000. This excludes other taxes and policy charges.Modeled: stated assumptionsConditional arithmetic under Section 702(c)(3) | The tool does not allocate BMA licence fees to a policy or calculate Bermuda stamp duty. Obtain a carrier quote and determine any US excise exposure separately.Requires reviewIssuer-specific fees and taxes | CIMA licence fees are insurer-level charges. They are not automatically per-policy costs. The calculator excludes Cayman stamp duty because it does not collect the sum insured or a confirmed duty treatment.Requires reviewCIMA fees; actual policy charge review | CAA supervisory fees are insurer-level charges. They cannot be allocated to one policy without evidence. Obtain the full policy charge schedule and analyze any foreign-insurance excise separately.Requires reviewCAA supervisory fees; carrier quote review |
| Policy-loan considerations | Section 2932(e) disapplies specified ordinary-life provisions, including Section 2911, to variable life. Review the applicable variable-contract rules and the actual loan, collateral and repayment terms.Source-supported18 Del. C. Sections 2911 and 2932(e) | The Life Insurance Act addresses disclosure of surrender and loan options, if any. Its governing-law and contract scope must be checked before applying those provisions.Source-supportedLife Insurance Act 1978 Sections 2 and 4 | Obtain the policy loan provisions and confirm applicable approval and collateral conditions. The CIMA Investment Activities Rule also addresses lending for investment purposes; that provision should not be equated with a universal policyholder loan right.Requires reviewCIMA Investment Activities Rule Sections 6.5-6.6 | Article 115 of the insurance-contract law addresses the policyholder right to an advance and beneficiary consent after acceptance. Articles 116-117 address pledging. Governing law and actual terms still need review.Source-supportedLaw of July 27, 1997, Articles 115-117 |
| Asset-protection framework | Section 2932(a)(5) makes assets insurer-owned. Contract-conditioned insulation covers the portion equal to reserves and other contract liabilities. This is distinct from protection against a policyholder creditor.Source-supported18 Del. C. Section 2932(a)(5) | For a company using the Segregated Accounts Companies Act, review Sections 9, 12, 17 and 17A, including documented allocation, written recourse terms and internal transactions. A segregated account is not a separate legal person.Source-supportedSegregated Accounts Companies Act 2000 Sections 9, 12, 17 and 17A | Companies Act Section 221 permits secondary recourse to general assets only on a portfolio shortfall, unless articles prohibit it, and above required minimum capital. Other portfolios are excluded. An SPC portfolio and a separate PIC are different structures.Source-supportedCompanies Act, 2026 Revision, Sections 218, 220-221; PIC provisions | Articles 117-119 address matching assets and creditor privileges. Winding-up provisions, including Article 253-5, distinguish pools and shortage allocation. The policyholder has claims and statutory priorities, not personal title to every underlying asset.Source-supportedInsurance-sector law Articles 117-119 and 253-5 |
| Cross-border considerationsDifferent legal or commercial objects | Confirm state-specific authority, solicitation, delivery and servicing before a transaction or move. Delaware surplus-lines provisions exclude life and health insurance from that route.Requires review18 Del. C. Sections 1904 and 1905; distribution review | Bermuda registration does not establish permission to solicit or service a person in another country. Obtain the issuing and destination-country distribution analysis.Requires reviewCross-border authorisation review | Cayman authorisation does not establish permission to sell or service a policy in the owner country. Review domestic-business limits and destination-country requirements separately.Requires reviewCIMA licence scope; destination-country review | EEA distribution rules and destination-country requirements must be checked for the actual transaction. The Swiss-EU insurance agreement concerns specified non-life establishment, not a general life-insurance passport.Requires reviewFINMA international treaties; authorisation review |
| US-taxpayer relevance | A domestic issuing-insurer scenario does not attract the foreign-insurance charge under Section 4371. Income-tax qualification, access to policy value and estate inclusion are separate questions.Source-supportedIRS Publication 510, foreign insurance taxes | Foreign life-policy excise scope refers to the insured life under Section 4372(e). Bermuda treaty relief is restricted; a valid Section 953(d) election or a separate statutory exemption requires issuer-specific evidence.Source-supportedIRC Sections 4371, 4372(e), 4373; Rev. Proc. 2003-47 | Section 4372(e) refers to the insured US citizen or resident. A non-US owner does not by itself remove excise exposure. Confirm any valid Section 953(d) election or separate Section 4373 exemption.Source-supportedIRC Sections 4371, 4372(e), 4373; Rev. Proc. 2003-47 | IRS guidance lists Luxembourg treaty relief for qualifying direct-insurance premiums. Confirm treaty residence, transaction scope and an effective issuer closing agreement. Listing alone does not establish exemption.Source-supportedIRS Section 4371 treaty guidance |
| Estate-planning considerationsDifferent legal or commercial objects | Review proceeds receivable by the estate, retained incidents of ownership and relevant transfers under Sections 2042 and 2035. Trust ownership does not by itself establish exclusion.Requires reviewIRC Sections 2042 and 2035; fact-specific estate review | Stamp Duties Act Section 47 addresses estate affidavits and Bermuda-situs property, with exclusions. This differs from a general statement that Bermuda has no estate-related charges.Source-supportedStamp Duties Act 1976 Section 47 | Do not infer the owner or beneficiary tax result from the absence of a similarly named Cayman tax statute. Determine applicable succession law, foreign-country taxes and any actual tax undertaking.Requires reviewCountry-specific estate and tax review | Luxembourg succession-tax guidance distinguishes resident and nonresident estates and addresses life insurance. The issuer domicile alone does not determine the family estate or beneficiary tax result.Requires reviewGuichet.lu succession-tax guidance; family-specific review |
| Reporting considerations | Domestic policy ownership does not settle every reporting obligation. Review foreign trusts, other foreign financial assets and each filing definition separately.Requires reviewForm 3520 instructions; structure-specific review | Review the applicable FATCA agreement, CRS definitions and domestic filing rules. The issuer classification and reportable-account tests are separate from the owner personal returns.Requires reviewUS Treasury FATCA agreements; Bermuda CRS framework | Cayman operates FATCA and CRS reporting frameworks. DITC amended-CRS guidance distinguishes changes effective in 2026 from first reporting in 2027. Apply the entity and account definitions, not a blanket all-policy rule.Source-supportedDITC amended CRS quick guide | Luxembourg CRS guidance covers cash-value insurance and reporting entities, subject to applicable definitions and exclusions. Institutional reports do not replace the owner separate filing obligations.Requires reviewLuxembourg CRS guidance and applicable FATCA agreement |
| Carrier ecosystemDifferent legal or commercial objects | Use the Delaware DOI licensee lookup and the issuing insurer documents. Registration alone does not establish a PPLI offer, current minimum premium, asset acceptance or availability to a client.Requires reviewDelaware DOI licensee lookup; carrier due diligence | The BMA regulated-entities register is a starting point for checking the issuer. Confirm the actual product, assets, policy terms and client acceptance directly.Requires reviewBMA regulated entities register | Use CIMA entity search to check the named issuer, then obtain evidence of its actual insurance offering. Licence counts are not counts of PPLI products or available policies.Requires reviewCIMA entity search; issuer due diligence | Use the CAA life-insurer register to identify authorised entities. Confirm the actual product, jurisdiction of sale and acceptance criteria directly; a registry entry is not a PPLI offer.Requires reviewCAA life-insurer register |
| Market dataDifferent legal or commercial objects | Broad life-insurance statistics and a survey of selected PPLI providers measure different populations. This engine does not estimate a complete US PPLI market size.Requires reviewSource-linked market research | The BMA long-term insurance report describes a broad insurance population. Its asset and premium measures do not by themselves establish the size or performance of PPLI.Requires reviewBMA long-term insurance market report; scope limitation | CIMA reports 721 international Class B, C and D insurers at June 30, 2026. The total spans different insurance activities and is not a count of PPLI issuers.Source-supportedCIMA Insurance Statistics, Q2 2026 | CAA reports EUR279.42B of life-insurer technical commitments at end-Q2 2026, with unit-linked commitments above 80%. These broad insurance figures are not US PPLI market size.Source-supportedCAA Q2 2026 press release |
| Pending change | Review federal legislative status and Delaware proposals for the actual transaction date. This dataset does not claim there are no pending changes.Requires reviewDelaware DOI proposed regulations | Bermuda corporate income tax began for in-scope groups in 2025. Separately check current BMA rules and consultations; this dataset does not assert that none affects the proposed policy.Requires reviewBermuda corporate income tax guidance; current regulatory review | Review CIMA notices, consultations and DITC reporting changes for the relevant date. This dataset does not certify that there are no pending insurance changes.Requires reviewCIMA industry notices; DITC updates | Circulars 26/1 and 26/2 took effect February 1, 2026. Section 10 of 26/1 preserves specified prior rules for existing contracts and funds; legacy treatment must be checked rather than dismissed as obsolete.Source-supportedCAA Circular 26/1 Section 10; Circular 26/2 |
| Key limitations | Contract-conditioned account protection, actual investment permissions, loan terms, tax allocation and possible guaranty exclusions require issuer-specific review.Requires reviewCountry research and the source-linked fields above | Confirm the governing account regime, recourse clauses, custody, permitted investments, issuer tax status and foreign-country treatment. Registration alone does not resolve those issues.Requires reviewCountry research and the source-linked fields above | Confirm whether the policy uses an SPC, PIC or another structure, the articles and recourse terms, applicable amendments, stamp treatment and the issuing entity tax status.Requires reviewCountry research and the source-linked fields above | Confirm the contract governing law, asset category, deposit arrangement, cash treatment, claim priority, US-control constraints and any treaty or other tax assumptions.Requires reviewCountry research and the source-linked fields above |
| Where it may be less appropriate | Further evidence is needed where the intended investments, servicing country, liquidity terms or tax assumptions cannot be confirmed for a specific domestic policy.Requires reviewCountry research and the source-linked fields above | Additional diligence is needed where the required investment, custody, tax or servicing conditions have not been documented for the issuing entity and policy.Requires reviewCountry research and the source-linked fields above | Further evidence is needed where the account structure, general-asset recourse, policy permissions or cross-border tax assumptions have not been documented.Requires reviewCountry research and the source-linked fields above | Additional review is needed where investment-selection rights conflict with US tax constraints, category requirements are unmet, or the intended distribution, custody or tax treatment cannot be confirmed.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.
Jurisdictions outside this calculator
Liechtenstein, Singapore and Switzerland remain available as linked country research.
These articles address additional jurisdictions. They do not feed the four-country arithmetic or source-coverage percentages. A complete engine profile would require the same twenty fields, the relevant sources and clearly scoped contract assumptions.
Liechtenstein Outside this dataset
See the linked source-based country article. This jurisdiction is outside the four-country calculator dataset.
- A completed dataset across the same twenty dimensions
- Issuer-specific investment, custody and policy terms
- Country-specific tax, distribution and reporting analysis
Singapore Outside this dataset
See the linked source-based country article. This jurisdiction is outside the four-country calculator dataset.
- A completed dataset across the same twenty dimensions
- Issuer-specific investment, custody and policy terms
- Country-specific tax, distribution and reporting analysis
Switzerland Outside this dataset
See the linked source-based country article. This jurisdiction is outside the four-country calculator dataset.
- A completed dataset across the same twenty dimensions
- Issuer-specific investment, custody and policy terms
- Country-specific tax, distribution and reporting analysis
Methodology
What each input changes and how source coverage is calculated.
What the engine evaluates
The engine displays statutory and regulatory research, flags documentation gaps and calculates selected premium-tax or excise components. The dataset covers the United States through a Delaware framework, Bermuda, Cayman Islands and Luxembourg. The US profile is not a fifty-state survey.
What it does not evaluate
It does not underwrite an insured life, confirm a carrier offer, approve investments, test a particular contract under Section 7702, determine investor control, estimate investment returns or calculate full policy costs. Tax residence and citizenship are not a complete legal profile.
The three opening inputs
Tax residence selects certain country-review reminders. US-person status selects US tax questions. The allocation band supplies a disclosed arithmetic amount. Closed bands use their midpoint. The US$250 million-plus band uses its lower bound, because it has no midpoint. An exact positive premium can replace the band amount.
Optional refinements
The Delaware schedule, excise scope, issuer election and treaty assumptions change tax arithmetic. Trust ownership and single-life status are necessary inputs for the illustrated Section 702(c)(3) case, but do not prove all legal conditions. Portfolio allocation, SMAs, horizon, beneficiary locations and relocation change review reminders. They do not project returns or alter statutory rates.
Research priorities and weights
The defaults assign weight 3 to investment flexibility, asset protection, investment-manager access and cross-border matters; weight 2 to regulatory framework, cost, carrier availability and estate planning; weight 1 to custody, loans, portability and administrative simplicity; and weight 0 to currency flexibility. Selecting up to three priorities assigns those weight 3 and all others weight 1. These editorial weights organize research coverage, not investment merit.
| Priority | Mapped fields |
|---|---|
| Investment flexibility | Investment architecture, IDF / SMA availability |
| Regulatory framework | Statutory framework, Licence class |
| Carrier availability | Carrier ecosystem |
| Cost | Premium-tax considerations |
| Currency flexibility | Currency considerations |
| Cross-border | Cross-border considerations |
| Estate planning | Estate-planning considerations |
| Asset protection | Asset-protection framework |
| Investment-manager access | No mapped field; coverage remains open |
| Custody | Custody considerations |
| Policy loans | Policy-loan considerations |
| Portability | Cross-border considerations, Reporting considerations |
| Administrative simplicity | No mapped field; coverage remains open |
A priority counts as covered only if it has at least one mapped field and every mapped field is source-supported. Unmapped or incomplete priorities remain in the weight denominator. This exposes missing research instead of awarding a favorable score for silence. Personal-status reminders do not change whether a source exists.
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 authorisation 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 positive premium used in the illustration. A blank exact-premium field uses the disclosed band assumption. An invalid amount leaves the tax result undetermined.
Weighted source coverage
Sum of weights for covered priorities ÷ sum of all assigned weights. A covered priority has at least one mapped field, all marked source-supported.
Field coverage
Source-supported non-derived fields ÷ eighteen non-derived fields. The two summary rows are excluded. Percentages are rounded for display.
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).
Delaware qualifying private placement
0.02 × min(P, 100,000), assuming Section 702(c)(3) applies to that policy and calendar year.
Selected foreign-life excise scenario
0.01 × ceiling(P), where ceiling rounds up to the next whole dollar. A selected valid issuer election, applicable Luxembourg treaty relief, or separate outside-scope/exempt assumption changes this modeled component to zero. Unconfirmed scope remains undetermined.
Basis points
Illustrated component ÷ P × 10,000. This expresses that component relative to premium; it is not an annual expense ratio or a full policy-cost measure.
Section 4373 includes possible exemptions, including qualifying effectively connected income. A valid Section 953(d) election is not the only possible route. 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 2026-09-17.
- Delaware Department of Insurance
Company Regulation Division. United States. - Delaware Code Online
18 Del. C. Section 2932; 18 Del. C. Section 2932(a)(2)-(4); 18 Del. C. Sections 2911 and 2932(e); 18 Del. C. Section 2932(a)(5). United States. - Delaware Department of Insurance
Issuer-specific authorisation review; Delaware DOI licensee lookup; carrier due diligence. United States. - eCFR; IRS
Treasury Regulation 1.817-5(b), (f). United States. - Delaware Code Online
Contract and form-approval review. United States. - Delaware Administrative Code
18 Del. Admin. Code 1205; issuer custody review. United States. - Delaware Code Online
18 Del. C. Section 702(a)-(c); Conditional arithmetic under Section 702(c)(3). United States. - Delaware Code Online
18 Del. C. Sections 1904 and 1905; distribution review. United States. - IRS
IRS Publication 510, foreign insurance taxes. United States. - US Code
IRC Sections 2042 and 2035; fact-specific estate review. United States. - IRS
Form 3520 instructions; structure-specific review. United States. - PPLI.com research
Source-linked market research. United States. - Delaware Department of Insurance
Delaware DOI proposed regulations. United States. - PPLI.com research
Country research and the source-linked fields above. United States. - Bermuda Monetary Authority
Insurance Act 1978, as amended; Insurance Act 1978; related contract and account legislation; Insurance Act 1978 Sections 4EB-4EF; Issuer-specific fees and taxes; Cross-border authorisation review. Bermuda. - Bermuda Monetary Authority
Insurance Code of Conduct Section 5.1.2. Bermuda. - Bermuda Monetary Authority
Carrier investment approval and federal tax review. Bermuda. - Bermuda Monetary Authority
Insurance Account Rules 2016 rule 13. Bermuda. - Bermuda Laws
Financial Services Tax Act 2017 Sections 2 and 4. Bermuda. - Bermuda Monetary Authority
Life Insurance Act 1978 Sections 2 and 4. Bermuda. - Bermuda Laws
Segregated Accounts Companies Act 2000 Sections 9, 12, 17 and 17A. Bermuda. - US Code; IRS
IRC Sections 4371, 4372(e), 4373; Rev. Proc. 2003-47. Bermuda, Cayman Islands. - Bermuda Laws
Stamp Duties Act 1976 Section 47. Bermuda. - US Treasury; applicable Bermuda reporting framework
US Treasury FATCA agreements; Bermuda CRS framework. Bermuda. - Bermuda Monetary Authority
BMA regulated entities register. Bermuda. - Bermuda Monetary Authority
BMA long-term insurance market report; scope limitation. Bermuda. - BMA; Government of Bermuda
Bermuda corporate income tax guidance; current regulatory review. Bermuda. - PPLI.com research
Country research and the source-linked fields above. Bermuda. - CIMA
CIMA insurance supervision and licence FAQs; CIMA insurance licence FAQs; CIMA licence scope; destination-country review. Cayman Islands. - CIMA; Cayman Islands Legislation
CIMA acts and regulations index. Cayman Islands. - Cayman Islands Legislation; CIMA
CIMA Investment Activities Rule Sections 6.2.5 and 6.3.2; Insurance Act Sections 16-17; CIMA Investment Activities Rule Sections 6.3 and 6.4; CIMA Investment Activities Rule Section 6.2.1; CIMA Investment Activities Rule Sections 6.5-6.6. Cayman Islands. - CIMA
CIMA Investment Activities guidance; Insurance Act Section 15. Cayman Islands. - Cayman Islands legislation
Stamp Duty Act, 2019 Revision, life-policy schedule. Cayman Islands. - CIMA
CIMA fees; actual policy charge review. Cayman Islands. - Cayman Islands Legislation
Companies Act, 2026 Revision, Sections 218, 220-221; PIC provisions. Cayman Islands. - Cayman Islands Legislation; General Registry
Country-specific estate and tax review. Cayman Islands. - Department for International Tax Cooperation
DITC amended CRS quick guide. Cayman Islands. - CIMA
CIMA entity search; issuer due diligence. Cayman Islands. - CIMA
CIMA Insurance Statistics, Q2 2026. Cayman Islands. - CIMA
CIMA industry notices; DITC updates. Cayman Islands. - PPLI.com research
Country research and the source-linked fields above. Cayman Islands. - Commissariat aux Assurances
CAA. Luxembourg. - Commissariat aux Assurances
CAA Circular 26/1 Section 10; insurance-sector law; CAA Circular 26/1 Sections 2 and 7.3.2; CAA Circular 26/1 Sections 7.3.1 and 7.4; CAA Circular 26/1 Section 10; Circular 26/2. Luxembourg. - Commissariat aux Assurances
Insurance-sector law Annex II. Luxembourg. - Commissariat aux Assurances
RCAA 15/3; contract-specific review. Luxembourg. - Commissariat aux Assurances
CAA Circular 16/9, coordinated February 1, 2026. Luxembourg. - Guichet.lu; transaction-specific tax review
Cross-border premium-tax and stamp-duty review. Luxembourg. - Commissariat aux Assurances
CAA supervisory fees; carrier quote review. Luxembourg. - Commissariat aux Assurances
Law of July 27, 1997, Articles 115-117. Luxembourg. - Commissariat aux Assurances
Insurance-sector law Articles 117-119 and 253-5. Luxembourg. - FINMA
FINMA international treaties; authorisation review. Luxembourg. - IRS
IRS Section 4371 treaty guidance. Luxembourg. - Guichet.lu
Guichet.lu succession-tax guidance; family-specific review. Luxembourg. - US Treasury; Administration des contributions directes
Luxembourg CRS guidance and applicable FATCA agreement. Luxembourg. - Commissariat aux Assurances
CAA life-insurer register. Luxembourg. - Commissariat aux Assurances
CAA Q2 2026 press release. 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 and Section 817.
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.
- Source coverage is not a recommendation. More documented fields can reflect the dataset's scope or available instruments. It does not prove stronger protection or a better policy.
- 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 corrects the source summaries, tax assumptions and calculation scope checked on September 17, 2026. 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 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.