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Taxation
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Taxation Taxation
Under Swiss law through December 31, 2024, a resident company is subject to income tax at the federal, cantonal, and communal levels that is levied on net worldwide income. Income attributable to permanent establishments or real estate located abroad is excluded from the Swiss tax base. Furthermore, participation relief (i.e., tax relief) is granted to Chubb Limited at the federal, cantonal, and communal level for qualifying dividend income. Chubb Limited is subject to an annual cantonal and communal capital tax on the taxable equity of Chubb Limited in Switzerland.

Chubb has two Swiss operating subsidiaries, an insurance company, Chubb Insurance (Switzerland) Limited and a reinsurance company, Chubb Reinsurance (Switzerland) Limited. Both are subject to federal, cantonal, and communal income tax and to annual cantonal and communal capital tax.

Under Bermuda law, Chubb Limited and its Bermuda subsidiaries are not required to pay any taxes on income or capital gains. However, on December 27, 2023, the Government of Bermuda enacted the Corporate Income Tax Act of 2023 which established a 15 percent income tax on net taxable income of Bermuda entities effective January 1, 2025. Chubb's Bermuda subsidiaries will pay taxes on their income beginning in 2025.

Income from Chubb's operations at Lloyd's is subject to United Kingdom (U.K.) corporation income taxes. Lloyd's is required to pay U.S. income tax on U.S. connected income written by Lloyd's syndicates. Lloyd's has a closing agreement with the Internal Revenue Service (IRS) whereby the amount of tax due on this business is calculated by Lloyd's and remitted directly to the IRS. These amounts are then charged to the accounts of Chubb's Corporate Members in proportion to their participation in the
relevant syndicates. Chubb's Corporate Members are subject to this arrangement but, as U.K. domiciled companies, will receive U.K. corporation tax credits for any U.S. income tax incurred up to the value of the equivalent U.K. corporation income tax charge on this income.

Chubb Group Holdings and its respective subsidiaries are subject to income taxes imposed by U.S. authorities and file a consolidated U.S. Federal income tax return. Should Chubb Group Holdings pay a dividend to Chubb Limited, withholding taxes would apply. Currently, however, no withholding taxes are accrued with respect to such un-remitted earnings as management has no intention of remitting these earnings. Similarly, no taxes have been provided on the un-remitted earnings of certain foreign subsidiaries (Chubb Life Insurance Hong Kong and Chubb Life Insurance Korea Company Ltd.) as management has no intention of remitting these earnings. Finally, we have made a partial reinvestment assertion on historical earnings for LINA Life Insurance Company of Korea and Huatai Insurance Group Co., Ltd. The cumulative amount that would be subject to withholding tax, if distributed, as well as the determination of the associated tax liability are not practicable to compute; however, such amount would be material.

Certain international operations of Chubb are also subject to income taxes imposed by the jurisdictions in which they operate. Chubb's domestic operations are in Switzerland, the jurisdiction where we are legally organized, incorporated, and registered.

The following table presents pre-tax income and the related provision for income taxes:
Year Ended December 31
(in millions of U.S. dollars)202420232022
Pre-tax income:
      Switzerland$121 $44 $234 
      Outside Switzerland11,334 9,482 6,251 
      Total pre-tax income$11,455 $9,526 $6,485 
Provision for income taxes
Current tax expense:
      Switzerland$29 $25 $15 
      Outside Switzerland1,700 1,570 1,066 
      Total current tax expense1,729 1,595 1,081 
Deferred tax expense (benefit):
      Switzerland14 (63)34 
      Outside Switzerland72 (1,021)124 
      Total deferred tax expense (benefit)86 (1,084)158 
Provision for income taxes$1,815 $511 $1,239 

The most significant jurisdictions contributing to the overall taxation of Chubb are calculated using the following rates in 2024: Switzerland 19.7 percent, U.S. 21.0 percent, U.K. 25.0 percent, and Bermuda 0.0 percent.

The following table presents a reconciliation of the difference between the provision for income taxes and the expected tax provision at the Swiss statutory income tax rate:
Year Ended December 31
(in millions of U.S. dollars)20242023 2022 
Expected tax provision at Swiss statutory tax rate$2,251 $1,872 $1,274 
Permanent differences:
Taxes on earnings subject to rate other than Swiss statutory rate(510)(389)(243)
Bermuda tax law enactment(55)(1,135)— 
Net withholding taxes145 15 75 
Other(16)148 133 
Provision for income taxes$1,815 $511 $1,239 
Current income tax receivable of $246 million and $266 million at December 31, 2024 and 2023, respectively, was recorded in Other assets on the Consolidated balance sheets. Current income tax payable of $376 million and $330 million at December 31, 2024 and 2023, respectively, was recorded in Accounts payable, accrued expenses, and other liabilities on the Consolidated balance sheets.

The following table presents the components of net deferred tax assets and liabilities:
December 31
(in millions of U.S. dollars)2024 2023 
Deferred tax assets:
Loss reserve discount$1,746 $1,643 
Unearned premiums reserve753 678 
Foreign tax credits18 19 
Loss carry-forwards146 149 
Investments (1)
512 524 
Depreciation26 37 
Future policy benefits176 (42)
Other268 189 
Total deferred tax assets 3,645 3,197 
      Valuation allowance1,081 716
      Deferred tax assets, net of valuation allowance2,564 2,481 
Deferred tax liabilities:
Deferred policy acquisition costs1,005 675 
Other intangible assets, including VOBA1,289 1,444 
Un-remitted foreign earnings251 176 
Total deferred tax liabilities 2,545 2,295 
Net deferred tax assets (liabilities)$19 $186 
(1)Included in Investments are deferred taxes on unrealized depreciation of $787 million and $662 million at December 31, 2024 and 2023, respectively.

The valuation allowance of $1.1 billion and $716 million at December 31, 2024 and 2023, respectively, reflects management's assessment, based on available information, that it is more likely than not that a portion of the deferred tax assets will not be realized due to the inability of certain subsidiaries to generate sufficient taxable income. Adjustments to the valuation allowance are made when there is a change in management's assessment of the amount of deferred tax assets that are realizable.

For the year ended December 31, 2024, the tax benefit on certain unrealized capital losses in our investment portfolio was reduced by a valuation allowance of $633 million necessary due to limitations on the utilization of these losses for tax purposes. As part of evaluating whether it was more likely than not that we could record a tax benefit on these losses, we considered realized gains, carryback capacity and available tax planning strategies.

At December 31, 2024, Chubb has net operating loss carry-forwards of $500 million which, if unused, will expire starting in 2025, and a U.S. life capital loss carry-forward of $26 million which, if unused, will expire starting in 2028.
The following table presents a reconciliation of the beginning and ending amount of gross unrecognized tax benefits:
Year Ended December 31
(in millions of U.S. dollars)2024 2023 
Balance, beginning of year$73 $67 
Additions based on tax positions related to the current year1 — 
Additions based on tax positions related to prior years57 9 
Reductions for settlements with taxing authorities(1)(3)
Balance, end of year$130 $73 

At December 31, 2024 and 2023, the gross unrecognized tax benefits of $130 million and $73 million, respectively, can be reduced by $18 million and $19 million, respectively, associated with foreign tax credits. The net amounts of $112 million and $54 million at December 31, 2024 and 2023, respectively, if recognized, would favorably affect the effective tax rate. It is reasonably possible that over the next twelve months, that the amount of unrecognized tax benefits may change further resulting from the re-evaluation of unrecognized tax benefits arising from examinations by taxing authorities and the lapses of statutes of limitations.

Chubb recognizes accruals for interest and penalties, if any, related to unrecognized tax benefits in Income tax expense in the Consolidated statements of operations. Tax-related interest expense and penalties reported in the Consolidated statements of operations were $6 million, $7 million, and $4 million at December 31, 2024, 2023, and 2022, respectively. Liabilities for tax-related interest and penalties in our Consolidated balance sheets were $30 million and $25 million at December 31, 2024 and 2023, respectively.

In March 2017, the IRS commenced its field examination of Chubb Group Holdings’ U.S. Federal income tax returns for 2014 and 2015 which is still ongoing. In July 2020, the IRS commenced its field examination of Chubb Group Holdings' U.S. Federal income tax returns for 2016, 2017 and 2018 which is also still ongoing. No material adjustments have been proposed by the IRS for any year under examination. As a multinational company, we also have examinations under way in non-US jurisdictions. With few exceptions, Chubb is no longer subject to income tax examinations for years prior to 2012.

The following table summarizes tax years open for examination by major income tax jurisdiction:
At December 31, 2024
Australia2018-2024
Brazil2018-2024
Canada2012-2024
China2021-2024
France 2022-2024
Germany2016-2024
Italy2019-2024
Korea2019-2024
Mexico2016-2024
Spain2012-2024
Switzerland2019-2024
United Kingdom2015-2024
United States2014-2024