SiriusPoint LtdSPNT
SiriusPoint Ltd Income Taxes Disclosure
16. Income taxes
The Company provides for income tax expense or benefit based upon pre-tax income or loss reported in the consolidated statements of income and the provisions of currently enacted tax laws. For the years ended December 31, 2024 and 2023, the Company and its subsidiaries organized in Bermuda were not subject to income taxes imposed by the government of Bermuda. Effective January 1, 2025, a 15% corporate income tax is applied to our Bermuda operations as a result of the enactment of the Corporate Income Tax Act 2023 (the “Bermuda CIT”) on December 27, 2023. The Bermuda CIT legislation includes specific provisions intended to administer a fair and equitable transition into the new tax system, referred to as the economic transition adjustment (“ETA”) and opening tax loss carryforward (“OTLC”). SiriusPoint Ltd. and at least one of its major subsidiaries organized and operating in Bermuda will be subject to these provisions. As a result, in the fourth quarter of 2023 (the period of enactment), the Company recorded a net deferred tax asset of $100.8 million in connection with the Bermuda CIT. An additional $34.6 million benefit was recorded during in 2024 after finalization of results. Following technical amendments enacted in December 2025, a $13.0 million benefit was recorded.
The Company has subsidiaries and branches that operate in various other jurisdictions around the world that are subject to tax in the jurisdictions in which they operate. The jurisdictions in which the Company's subsidiaries and branches are subject to tax are Bermuda, Belgium, Canada, Luxembourg, Sweden, Switzerland, the United Kingdom, and the United States.
The following is a summary of the Company’s income before income tax (expense) benefit by jurisdiction for the years ended December 31, 2025, 2024 and 2023:
| 2025 | 2024 | 2023 | |||||||||||||||
| Bermuda | $ | 25.1 | $ | 53.7 | $ | 21.5 | |||||||||||
United States (1) | 384.8 | 89.6 | 98.6 | ||||||||||||||
| United Kingdom | 54.3 | 4.1 | 2.7 | ||||||||||||||
| Sweden | 72.7 | 86.1 | 156.7 | ||||||||||||||
| Luxembourg | 4.1 | 0.1 | 38.1 | ||||||||||||||
| Other | 0.3 | (0.5) | 1.1 | ||||||||||||||
| Income before income tax (expense) benefit | $ | 541.3 | $ | 233.1 | $ | 318.7 | |||||||||||
(1)The pre-tax income in the United States is primarily driven by the sale of a subsidiary group during the year.
For the years ended December 31, 2025, 2024 and 2023, income tax (expense) benefit consisted of the following:
| 2025 | 2024 | 2023 | |||||||||||||||
| Current tax (expense) benefit: | |||||||||||||||||
| U.S. Federal | $ | (44.5) | $ | (6.1) | $ | (17.0) | |||||||||||
| State | (5.7) | (1.1) | (1.4) | ||||||||||||||
| Non-U.S. | 2.0 | (12.6) | (13.9) | ||||||||||||||
| Total current tax expense | (48.2) | (19.8) | (32.3) | ||||||||||||||
| Deferred tax (expense) benefit: | |||||||||||||||||
| U.S. Federal | (25.9) | (15.4) | (3.7) | ||||||||||||||
| State | (5.8) | (1.3) | (0.3) | ||||||||||||||
| Non-U.S. | (1.3) | 5.8 | 81.3 | ||||||||||||||
| Total deferred tax (expense) benefit | (33.0) | (10.9) | 77.3 | ||||||||||||||
| Total income tax (expense) benefit | $ | (81.2) | $ | (30.7) | $ | 45.0 | |||||||||||
Effective Rate Reconciliation
In December 2023, the FASB issued ASU 2023-09 which intends to enhance the transparency and decision usefulness of income tax disclosures, requiring disaggregated information about an entity’s effective tax rate reconciliation, as well as income taxes paid. The Company adopted this accounting standard prospectively, effective for the year ended December 31,
2025. The following table presents a reconciliation of expected income tax (expense) benefit for the year ended December 31, 2025:
| 2025 | |||||||||||
| Amount | Percent | ||||||||||
| Bermuda Federal Statutory Tax Rate | $ | (81.1) | 15.0 | % | |||||||
| Effect of Changes in Tax Laws or Rates Enacted in the Current Period | 13.0 | (2.4) | % | ||||||||
| Other Adjustments | (3.7) | 0.7 | % | ||||||||
| Foreign Tax Effects | |||||||||||
| United States | |||||||||||
| Statutory tax rate difference | (23.1) | 4.3 | % | ||||||||
| State and Local Income Taxes | (4.5) | 0.8 | % | ||||||||
| Tax Credits | 1.2 | (0.2) | % | ||||||||
| Foreign Branches | (2.0) | 0.4 | % | ||||||||
| Impacts from Sale of Subsidiaries | (2.5) | 0.5 | % | ||||||||
| Provision-to-Return True Up | 4.3 | (0.8) | % | ||||||||
| Other | 2.4 | (0.4) | % | ||||||||
| Sweden | |||||||||||
| Statutory tax rate difference | (4.1) | 0.8 | % | ||||||||
| Tax Credits | 21.1 | (3.9) | % | ||||||||
| Foreign Branch - London | (13.3) | 2.5 | % | ||||||||
| Foreign Branch - Liege | (5.8) | 1.1 | % | ||||||||
| Foreign Branch - Zurich | (5.0) | 0.9 | % | ||||||||
| Foreign Currency Effects | 22.0 | (4.1) | % | ||||||||
| Adjustments to Deferred Tax Assets and Liabilities | (5.8) | 1.1 | % | ||||||||
| Annual Tax on Safety Reserve | (2.4) | 0.4 | % | ||||||||
| Other | 0.2 | (0.1) | % | ||||||||
| Luxembourg | |||||||||||
| Other | (1.0) | 0.2 | % | ||||||||
| United Kingdom | |||||||||||
| Statutory tax rate difference | (5.6) | 1.0 | % | ||||||||
| Changes in Valuation Allowances | 9.8 | (1.8) | % | ||||||||
| Provision-to-Return True Up | (1.5) | 0.3 | % | ||||||||
| Adjustments to Deferred Tax Assets and Liabilities | 6.8 | (1.3) | % | ||||||||
| Other | (0.6) | 0.1 | % | ||||||||
| Total income tax expense | $ | (81.2) | 15.1 | % | |||||||
The following table presents a reconciliation of expected income tax (expense) benefit for the years ended December 31, 2024 and 2023:
| 2024 | 2023 | ||||||||||
| Tax (expense) benefit at the statutory rate | $ | — | $ | — | |||||||
| Differences in taxes resulting from: | |||||||||||
| Bermuda Tax Law | 28.7 | 100.8 | |||||||||
| Non-Bermuda earnings | (39.9) | (73.1) | |||||||||
| Foreign currency effects | (9.1) | 9.1 | |||||||||
| Non-Taxable/Deductible Income | — | 7.6 | |||||||||
| Change in Valuation Allowance | 8.9 | (4.7) | |||||||||
| Tax on Safety Reserve | (3.1) | (2.3) | |||||||||
| Change in uncertain tax position | 1.4 | — | |||||||||
| Tax rate change | (8.4) | — | |||||||||
| State taxes expense | (0.9) | (1.4) | |||||||||
| Provision-to-return true up | (3.9) | 11.2 | |||||||||
| Non-Deductible expenses | (1.9) | (0.6) | |||||||||
| Foreign Branches | (1.4) | (1.3) | |||||||||
| Other, net | (1.1) | (0.3) | |||||||||
| Total income tax (expense) benefit | $ | (30.7) | $ | 45.0 | |||||||
The Tax Cuts and Jobs Act (“TCJA”) includes a Base Erosion and Anti-Abuse Tax (“BEAT”) provision, which is essentially a minimum tax on certain otherwise deductible payments made by U.S. entities to non-U.S. affiliates, including cross-border interest payments and reinsurance premiums paid or ceded. The statutory BEAT rate is 10% through 2025. The One Big Beautiful Bill Act (“OBBBA”) was signed into law in July 2025 which permanently enacted a 10.5% rate that applies to tax years 2026 and thereafter. The TCJA also includes provisions for Global Intangible Low-Taxed Income (“GILTI” later renamed “NCTI” (defined above) under OBBBA), under which taxes on foreign income are imposed on the excess of a deemed return on tangible assets of certain foreign subsidiaries. The Company has not been impacted by NCTI and forecasts no NCTI liability. Consistent with accounting guidance, the Company will treat BEAT as an in period tax charge when incurred in future periods for which no deferred taxes need to be provided. No provision for income taxes related to BEAT or NCTI was recorded as of December 31, 2025 and December 31, 2024.
The Organisation for Economic Co-Operation and Development (“OECD”) has published global anti-base erosion model rules under Pillar Two (the “GloBE Rules”), which implement a 15% global minimum tax applicable for in-scope multinational groups (“GMT”). Since January 1, 2024, the GloBE Rules have been effect in the EU and other jurisdictions, including a minimum top-up tax rate of 15% for multinational companies, with many E.U. member states enacting corollary legislation as part of their respective domestic tax laws. Consistent with accounting guidance, the Company will treat the global minimum tax as an in-period tax charge when incurred for which no deferred taxes need to be provided. No provision for top-up tax was recorded as of December 31, 2025, because, based on a country-by-country analysis, it has been determined that for each tested jurisdiction there would be no material amount of top-up tax.
The Company has capital and liquidity in many of its subsidiaries, some of which may reflect undistributed earnings. If such capital or liquidity were to be paid or distributed to the Company or to one of its intermediary subsidiaries as dividends or otherwise, they may be subject to withholding tax by the source country and/or income tax by the recipient country. The Company generally intends to operate, and manage its capital and liquidity, in a tax-efficient manner. It is not practicable to estimate the income tax liabilities that might be incurred if such earnings were remitted since it is driven by facts and laws at the time of distribution.
Tax Payments and Receipts
Net income taxes paid to national, state and local governments totaled $81.7 million for the year ended December 31, 2025 as
follows:
| 2025 | |||||
| U.S. Federal | $ | 32.0 | |||
| State | 6.0 | ||||
| Non-U.S. | 43.7 | ||||
| Total taxes paid | $ | 81.7 | |||
For the year ended December 31, 2025, income taxes paid, net of refunds, exceeded five percent of total income taxes paid, net of refunds, in the following jurisdictions as follows:
| 2025 | |||||
| State | |||||
| Maryland | $ | 4.0 | |||
| Non-U.S. | |||||
| Belgium | 7.2 | ||||
| Sweden | 21.0 | ||||
| United Kingdom | $ | 12.8 | |||
Deferred Tax Inventory
The following table presents the tax effects of temporary differences that give rise to the deferred tax assets and deferred tax liabilities as of December 31, 2025 and 2024:
| December 31, 2025 | December 31, 2024 | ||||||||||
| Deferred tax assets: | |||||||||||
| Non-U.S. net operating loss carryforwards | $ | 320.4 | $ | 308.1 | |||||||
| Tax credit carryforwards | 49.0 | 23.0 | |||||||||
| Unearned premiums | 24.3 | 20.0 | |||||||||
| U.S. federal net operating loss and capital carryforwards | 1.4 | 3.0 | |||||||||
| Discounting of loss and loss adjustment expense reserves | 19.5 | 18.1 | |||||||||
| Intangible assets | 36.9 | 84.8 | |||||||||
| Unrealized losses on investments | — | 6.6 | |||||||||
| Investment basis differences | 0.8 | 0.5 | |||||||||
| Foreign currency translation on investments | 1.9 | 1.5 | |||||||||
| Incentive compensation and benefit accruals | 5.4 | 3.9 | |||||||||
| Deferred interest | — | 3.2 | |||||||||
| Allowance for doubtful accounts | 3.0 | 4.0 | |||||||||
| Other items | 12.9 | 7.0 | |||||||||
| Total deferred tax assets | 475.5 | 483.7 | |||||||||
| Valuation allowance | (91.5) | (100.1) | |||||||||
| Total adjusted deferred tax asset | $ | 384.0 | $ | 383.6 | |||||||
| Deferred tax liabilities: | |||||||||||
| Safety reserve | $ | 130.6 | $ | 111.0 | |||||||
| Deferred acquisition costs | 26.5 | 19.7 | |||||||||
| Purchase accounting | 18.8 | 27.9 | |||||||||
| Unrealized gains on investments | 4.8 | — | |||||||||
| Other Items | 8.6 | 4.2 | |||||||||
| Total deferred tax liabilities | 189.3 | 162.8 | |||||||||
| Net deferred tax assets | $ | 194.7 | $ | 220.8 | |||||||
Of the net deferred tax asset, net of valuation allowance, of $194.7 million as of December 31, 2025, $9.4 million relates to net deferred tax assets in U.S. subsidiaries, $112.2 million relates to net deferred tax assets in Luxembourg subsidiaries, $144.0 million relates to net deferred tax assets in Bermuda subsidiaries, $9.4 million relates to net deferred tax liabilities in U.K. subsidiaries, $62.8 million relates to net deferred tax liabilities in Sweden subsidiaries, and $2.1 million and $0.8 million relates to net deferred tax assets and liabilities, respectively, in other jurisdictions.
The Company records a valuation allowance against deferred tax assets if it becomes more likely than not that all or a portion of deferred tax assets will not be realized. Changes in valuation allowances from period to period are included in income tax expense in the period of change. In determining whether or not a valuation allowance, or change therein, is warranted, the Company considers factors such as prior earnings history, expected future earnings, carryback and carryforward periods and strategies that if executed would result in the realization of a deferred tax asset. It is possible that certain planning strategies or projected earnings in certain subsidiaries may not be feasible to utilize the entire deferred tax asset, which could result in material changes to the Company's deferred tax assets and tax expense.
Based on this approach, for the year ended December 31, 2025, the Company recorded $91.5 million in the valuation allowance applicable to deferred tax assets. Of the $91.5 million, $66.5 million relates to net operating loss carryforwards in Luxembourg subsidiaries, $22.2 million relates primarily to net operating loss carryforwards in the United Kingdom, and $2.8 million relates to foreign tax credits in the United States.
Net Operating Loss and Capital Loss Carryforwards
Net operating loss and capital loss carryforwards as of December 31, 2025, the expiration dates and the deferred tax assets thereon are as follows:
| December 31, 2025 | |||||||||||||||||||||||||||||||||||||||||
| United States | Luxembourg | Sweden | U.K. | Germany | Bermuda | Total | |||||||||||||||||||||||||||||||||||
| 2030-2044 | $ | 7.3 | $ | 72.7 | $ | — | $ | — | $ | — | $ | — | $ | 80.0 | |||||||||||||||||||||||||||
| No expiration date | — | 682.1 | 132.4 | 85.2 | 2.6 | 604.6 | 1,506.9 | ||||||||||||||||||||||||||||||||||
| Total | $ | 7.3 | $ | 754.8 | $ | 132.4 | $ | 85.2 | $ | 2.6 | $ | 604.6 | $ | 1,586.9 | |||||||||||||||||||||||||||
| Gross deferred tax asset | $ | 1.5 | $ | 180.2 | $ | 27.3 | $ | 21.3 | $ | 0.8 | $ | 90.7 | $ | 321.8 | |||||||||||||||||||||||||||
| Valuation allowance | — | (66.5) | — | (21.3) | (0.8) | — | (88.6) | ||||||||||||||||||||||||||||||||||
| Net deferred tax asset | $ | 1.5 | $ | 113.7 | $ | 27.3 | $ | — | $ | — | $ | 90.7 | $ | 233.2 | |||||||||||||||||||||||||||
The Company expects to utilize net operating loss carryforwards in Luxembourg of $476.1 million but does not expect to utilize the remainder based on forecasted taxable income. The U.S. net operating loss carryforwards of $7.3 million are subject to an annual limitation on utilization under Internal Revenue Code Section 382 and will expire between 2036 and 2037. The Company expects to completely utilize the U.S. net operating loss carryforward.
Foreign Tax Credits
As of December 31, 2025, there are U.S. foreign tax credits carryforwards available of $6.9 million, all of which will expire between 2026 and 2033. There are Swedish foreign tax credits carryforwards available of $42.1 million and will start to expire in 2029.
Uncertain Tax Positions
Recognition of the benefit of a given tax position is based upon whether a company determines that it is more likely than not that a tax position will be sustained upon examination based upon the technical merits of the position. In evaluating the more likely than not recognition threshold, the Company must presume that the tax position will be subject to examination by a taxing authority with full knowledge of all relevant information. If the recognition threshold is met, then the tax position is measured at the largest amount of benefit that is more than 50% likely of being realized upon ultimate settlement.
The following table is a reconciliation of the beginning and ending unrecognized tax benefits for the years ended December 31, 2025 and 2024:
Permanent differences (1) | Temporary differences (2) | Interest and Penalties (3) | Total | ||||||||||||||||||||
| Balance as of January 1, 2024 | $ | 1.6 | $ | — | $ | 0.7 | $ | 2.3 | |||||||||||||||
| Lapse in statute of limitations | (0.8) | — | (0.6) | (1.4) | |||||||||||||||||||
| Balance as of December 31, 2024 | 0.8 | — | 0.1 | 0.9 | |||||||||||||||||||
| Changes in prior year tax positions | (0.7) | — | — | (0.7) | |||||||||||||||||||
| Balance as of December 31, 2025 | $ | 0.1 | $ | — | $ | 0.1 | $ | 0.2 | |||||||||||||||
(1)Represents the amount of unrecognized tax benefits that, if recognized, would impact the effective tax rate.
(2)Represents the amount of unrecognized tax benefits that, if recognized, would create a temporary difference between the reported amount of an item in the consolidated balance sheets and its tax basis.
(3)Net of tax benefit.
As of December 31, 2025, the total reserve for unrecognized tax benefits is $0.2 million. If the Company determines in the future that its reserves for unrecognized tax benefits on permanent differences and interest and penalties are not needed, the reversal of $0.1 million of such reserves as of December 31, 2025 would be recorded as an income tax benefit and would impact the effective tax rate.
The Company classifies all interest and penalties on unrecognized tax benefits as part of income tax expense. During the year ended December 31, 2025, the Company did not recognize interest expense, net of any tax benefit (2024 - none and 2023 - none). As of December 31, 2025, the balance of accrued interest, net of any tax benefit, is $0.1 million (2024 - $0.1 million).
Tax Examinations
With few exceptions, which are not material, the Company is no longer subject to U.S. federal, state or non-U.S. income tax examinations by tax authorities for years before 2021.
Historical Timeline
| Fiscal Year | Filed | |
|---|---|---|
| 2025 | Feb 24, 2026 | Showing above |
| 2024 | Feb 21, 2025 | |
| 2023 | Feb 29, 2024 | |
| 2022 | Feb 24, 2023 | |
| 2021 | Mar 1, 2022 | |
About Income Taxes Disclosures
The income tax disclosure reveals how much a company actually pays in taxes versus what the statutory rate would predict. Analysts focus on the effective tax rate (ETR) reconciliation, which breaks down every item driving the gap between the 21% federal rate and the company's reported ETR — including R&D credits, foreign rate differentials, and state taxes. Deferred tax assets (DTAs) and their valuation allowances signal management's confidence in future profitability: a rising allowance suggests the company doubts it can use accumulated tax benefits. Uncertain tax benefit (UTB) reserves quantify exposure to IRS challenges on aggressive positions.
Key signals to watch: sudden ETR drops without clear operational reasons, large increases in valuation allowances, growing UTB balances, and significant unremitted foreign earnings. Post-TCJA, pay attention to GILTI and BEAT provisions that affect multinational tax structures. Compare the cash taxes paid (from the cash flow statement) against the income tax provision to gauge earnings quality.