TAXATION
The Company is subject to income taxes in the jurisdictions in which it operates. The significant jurisdictions in which the Company is subject to tax are Bermuda, the U.S., Switzerland, and the U.K. Through December 31, 2024, RenaissanceRe and its Bermuda subsidiaries were not subject to any income or capital gains taxes in Bermuda. As a result of the enactment of the Bermuda Corporate Income Tax Act 2023 (“CIT”) on December 27, 2023, a 15% corporate income tax applies to tax years beginning on or after January 1, 2025 and is applicable to the Company’s Bermuda operations, except for the Bermuda operations of the Company’s joint ventures and managed funds. Furthermore, the Company’s profits generated in Bermuda on or after January 1, 2025 by the Company’s consolidated joint ventures and managed funds, except to the extent those profits are attributable to redeemable noncontrolling interests, are also taxed at 15% as a result of the enactment of Pillar II Rules by many of the jurisdictions in which the Company operates. The Company’s consolidated effective tax rate has increased in 2025 as a result of these changes.
RenaissanceRe Finance and its subsidiaries are subject to income taxes imposed by U.S. federal and state authorities and file a consolidated U.S. federal income tax return. Should RenaissanceRe Finance pay a dividend to its parent, withholding taxes would apply to the extent of current year or accumulated earnings and profits at an expected tax rate of 5.0%. The Company has not accrued withholding taxes on the
unremitted earnings of RenaissanceRe Finance to date as there is no intention to remit such earnings. The cumulative amount that would be subject to withholding tax, if distributed, is not practicable to compute.
The Company’s operations in the U.K. and Switzerland are subject to income taxes imposed by the respective jurisdictions in which they operate. Withholding taxes would not be expected to apply to dividends paid to RenaissanceRe from its operations in the U.K. and Switzerland.
Income Tax Expense
The following is a summary of the Company’s income (loss) before taxes allocated between domestic and foreign operations:
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| Year ended December 31, | 2025 | | 2024 | | 2023 | |
| Domestic (Bermuda) (1) | $ | 3,440,704 | | | $ | 2,574,104 | | | $ | 2,670,888 | | |
| Foreign (1) | 573,371 | | | 419,056 | | | 439,172 | | |
| Income (loss) before taxes | $ | 4,014,075 | | | $ | 2,993,160 | | | $ | 3,110,060 | | |
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(1)In prior years, the Company disclosed income (loss) before taxes disaggregated by jurisdiction. In 2025, in conjunction with the prospective adoption of ASU 2023-09 and the January 1, 2025 effective date of the CIT, the Company revised its presentation to disclose income (loss) before taxes disaggregated between Bermuda and foreign jurisdictions. This change is intended to more accurately reflect the geographic location where income (loss) before taxes is earned. Prior period amounts have been conformed to the current year presentation for comparability.
Income tax benefit (expense) is comprised as follows:
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| Year ended December 31, | 2025 | | 2024 | | 2023 | |
| Current income tax benefit (expense) | | | | | | |
| Federal (Bermuda) (1) | $ | (249,011) | | | $ | — | | | $ | — | | |
| Foreign | (138,981) | | | (56,718) | | | (57,422) | | |
| Total current income tax benefit (expense) | (387,992) | | | (56,718) | | | (57,422) | | |
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| Deferred income tax benefit (expense) | | | | | | |
| Federal (Bermuda) (1) | (13,262) | | | (346) | | | 593,765 | | |
| Foreign | 4,922 | | | 24,436 | | | (26,276) | | |
| Total deferred income tax benefit (expense) | (8,340) | | | 24,090 | | | 567,489 | | |
| Total income tax benefit (expense) | $ | (396,332) | | | $ | (32,628) | | | $ | 510,067 | | |
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(1)All Bermuda income taxes are levied by the Government of Bermuda and are considered federal income taxes in the context of FASB ASC 740, Income Taxes. As none of the parishes of Bermuda impose an income tax, the Company has not incurred any Bermuda state income tax benefit (expense).
The Company’s effective income tax rate, which it calculates as income tax benefit (expense) divided by income (loss) before taxes, may fluctuate from period to period depending on the geographic distribution of pre-tax income (loss) in any given period between different jurisdictions and the varying tax rates in each jurisdiction. The geographic distribution of pre-tax income (loss) can vary significantly between periods due to, but not limited to, the following factors: the business mix of net premiums written and earned; the geographic location, the size and the nature of net claims and claim expenses incurred; the amount and geographic location of operational expenses, net investment income, and net realized and unrealized gains (losses) on investments. A significant portion of the Company’s gross and net premiums are written and earned in Bermuda, which, prior to 2025, did not have a corporate income tax, resulting in a minimal income tax impact on the Company’s operations. As a result of the enactment of the CIT, the Company’s profits generated on or after January 1, 2025 in Bermuda (except for profits earned by the Company’s joint ventures and managed funds) are subject to a 15% corporate income tax. Furthermore, the profits generated in Bermuda on or after January 1, 2025 by its consolidated joint ventures and managed funds, except to the extent those profits are attributable to redeemable noncontrolling interests, are generally taxed at 15% as a result of the enactment of Pillar II Rules by many of the jurisdictions in which the Company operates.
A reconciliation of the difference between the provision for income taxes and the expected tax provision at the Bermuda statutory tax rate for 2025 after the adoption of ASU 2023-09 is as follows:
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| Year ended December 31, | 2025 | | | | | |
| | $ | | % | | | | | | | | | |
| Expected income tax benefit (expense) at Bermuda statutory tax rate | $ | (602,111) | | | 15.0 | % | | | | | | | | | |
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| Nontaxable or nondeductible items | | | | | | | | | | | | |
| Nontaxable income attributable to noncontrolling interests | 137,613 | | | (3.4) | % | | | | | | | | | |
| Subtotal | (464,498) | | | 11.6 | % | | | | | | | | | |
| Other nontaxable or nondeductible items | | | | | | | | | | | | |
| Other nontaxable income earned by excluded entities | 34,346 | | | (0.9) | % | | | | | | | | | |
| Other | 10,605 | | | (0.3) | % | | | | | | | | | |
| Foreign tax effects | | | | | | | | | | | | |
| U.K. | | | | | | | | | | | | |
| Pillar II top-up tax | (50,366) | | | 1.3 | % | | | | | | | | | |
| Change in valuation allowance | 40,838 | | | (1.0) | % | | | | | | | | | |
| Other | (19,139) | | | 0.5 | % | | | | | | | | | |
| Luxembourg | | | | | | | | | | | | |
| Change in valuation allowance | 38,827 | | | (1.0) | % | | | | | | | | | |
| Other | (3,927) | | | 0.1 | % | | | | | | | | | |
| U.S. | (35,462) | | | 0.9 | % | | | | | | | | | |
| Switzerland | (16,565) | | | 0.4 | % | | | | | | | | | |
| Other foreign jurisdictions | (2,265) | | | 0.1 | % | | | | | | | | | |
| Effect of changes in tax laws or rates enacted in the current period | 41,841 | | | (1.0) | % | | | | | | | | | |
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| Tax credits | | | | | | | | | | | | |
| Creditable foreign (non-Bermuda) taxes | 32,682 | | | (0.8) | % | | | | | | | | | |
| Changes in valuation allowances | — | | | — | % | | | | | | | | | |
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| Other adjustments | | | | | | | | | | | | |
| Other | (3,249) | | | 0.1 | % | | | | | | | | | |
| Income tax benefit (expense) and effective tax rate | $ | (396,332) | | | 9.9 | % | | | | | | | | | |
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A reconciliation of the difference between the provision for income taxes and the expected tax provision at the weighted average tax rate as presented in 2024 and 2023 prior to the adoption of ASU 2023-09 is as follows:
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| Year ended December 31, | | | 2024 | | 2023 | |
| Expected income tax benefit (expense) | | | $ | (60,684) | | | $ | (103,963) | | |
| Nondeductible expenses | | | (1,671) | | | (535) | | |
| Reinsurance adjustment | | | 4,384 | | | 4,746 | | |
| Effect of change in tax rate | | | (160) | | | (729) | | |
| Pillar II top-up tax | | | (16,603) | | | — | | |
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| GAAP to statutory accounting difference | | | (1,113) | | | (1,781) | | |
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| Withholding tax | | | (1,614) | | | (1,078) | | |
| Recognition of Bermuda net deferred tax asset | | | 8,339 | | | 593,765 | | |
| Change in valuation allowance | | | 66,198 | | | 45,192 | | |
| Foreign branch adjustments | | | (30,998) | | | (25,908) | | |
| Other | | | 1,294 | | | 358 | | |
| Income tax benefit (expense) | | | $ | (32,628) | | | $ | 510,067 | | |
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The Company’s expected income tax benefit (expense) shown in the table above was computed on pre-tax income (loss) at the weighted average tax rate calculated as the sum of the pre-tax income (loss) in each jurisdiction multiplied by that jurisdiction’s applicable statutory tax rate in effect for the relevant period.
Deferred Tax Assets and Liabilities
The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities are presented below:
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| At December 31, | 2025 | | 2024 | |
| Deferred tax assets | | | | |
| Intangible assets | $ | 382,183 | | | $ | 420,143 | | |
| Value of in-force business | 150,840 | | | 167,599 | | |
| Tax loss carryforwards | 135,107 | | | 152,864 | | |
| Reserve for claims and claim expenses | 143,158 | | | 131,121 | | |
| Unearned premiums | 51,520 | | | 59,441 | | |
| Amortization and depreciation | 25,761 | | | 23,877 | | |
| Deferred finance charges | 15,935 | | | 17,832 | | |
| Other | 5,598 | | | 8,571 | | |
| | 910,102 | | | 981,448 | | |
| Deferred tax liabilities | | | | |
| Deferred acquisition expenses | (75,558) | | | (125,347) | | |
| Investments | (36,123) | | | — | | |
| Deferred underwriting results | (22,399) | | | — | | |
| Deferred revenue | (14,458) | | | (8,685) | | |
| VOBA | — | | | (17,540) | | |
| Other | (14,572) | | | (7,312) | | |
| | (163,110) | | | (158,884) | | |
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| Net deferred tax asset (liability) before valuation allowance | 746,992 | | | 822,564 | | |
| Valuation allowance | (80,078) | | | (147,079) | | |
| Net deferred tax asset (liability) | $ | 666,914 | | | $ | 675,485 | | |
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At December 31, 2025, the Company recorded a net deferred tax asset of $666.9 million (2024 - $675.5 million), consisting of a deferred tax asset of $701.9 million (2024 - $701.1 million) and a deferred tax liability of $35.0 million (2024 - $25.6 million), which is included in other liabilities on the consolidated balance sheets.
The Company’s valuation allowance assessment is based on all available information including projections of future GAAP taxable income from each tax-paying component in each tax jurisdiction. A valuation allowance has been provided against certain deferred tax assets primarily related to deferred tax assets of RREAG, US Branch and certain net operating loss carryforwards in the U.K. During 2025, the Company recorded a net decrease to the valuation allowance of $67.0 million (2024 - decrease of $66.2 million, 2023 - increase of $19.6 million).
Net Operating Loss and Net Capital Loss Carryforwards
The Company has U.S. net operating loss carryforwards of $230.5 million which, under applicable law, will begin to expire in 2037. Additionally, the Company has net operating loss carryforwards of $102.3 million in the U.K. and $130.7 million in Luxembourg which, under applicable law, can be carried forward indefinitely. The Company has capital loss carryforwards of $126.1 million in the U.S. that begin to expire in 2026.
Income Taxes Paid
The Company made the following net tax payments in 2025 after the adoption of ASU 2023-09:
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| Year ended December 31, | 2025 | | | | | |
| Federal (Bermuda) | $ | 164,300 | | | | | | |
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| Foreign | | | | | | |
| U.S. | 39,239 | | | | | | |
| Switzerland | 14,161 | | | | | | |
| Other | 19,277 | | | | | | |
| Total net payment (refund) of income taxes | $ | 236,977 | | | | | | |
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The Company made net tax payments in 2024 and 2023 of $99.5 million and $26.8 million, respectively.
Unrecognized Tax Benefits
The Company had no unrecognized tax benefits that if recognized would affect the annual effective tax rate at December 31, 2025 (2024 - $Nill, 2023 - $Nil). Interest and penalties related to unrecognized tax benefits would be recorded in income tax benefit (expense) in the Company’s consolidated statements of operations. At December 31, 2025, there were no interest or penalties accrued on unrecognized tax benefits (2024 - $Nil, 2023 - $Nil).
Open Tax Years
The following tax years were open to examination by the local tax authorities as of February 6, 2026:
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| Tax Jurisdiction | | Open Tax Years | |
| Singapore | | 2021-2025 | |
| Ireland | | 2021-2025 | |
| U.S. | | 2018-2025 | |
| Australia | | 2021-2025 | |
| Switzerland | | 2020-2025 | |
| Luxembourg | | 2020-2025 | |
| Canada | | 2021-2025 | |
| U.K. | | 2022-2025 | |
| Bermuda | | 2025 | |
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The Company does not expect the resolution of these open years to have a significant impact on its consolidated statements of operations and financial condition.