International General Insurance Holdings Ltd.

74 Abdel Hamid Sharaf Street, P.O. Box 941428

Amman 11194, Jordan

September 24, 2024

VIA EDGAR

U.S. Securities & Exchange Commission
Division of Corporation Finance
Office of Finance
100 F Street, N.E.
Washington, D.C. 20549

Attn: Michael Volley and Amit Pande

Dear Mr. Volley and Mr. Pande:

On behalf of International General Insurance Holdings Ltd. (the “Company”), we are responding to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated September 17, 2024 (the “Comment Letter”), regarding the Company’s Form 20-F for fiscal year ended December 31, 2023 which was filed with the Commission on April 8, 2024 (the “20-F”).

Set forth below are the Company’s responses to the Staff’s comments in the Comment Letter. For reference purposes, the Staff’s comments are reproduced in bold below, followed by the Company’s response to the comment. The numbered paragraphs below correspond to the numbered comments in the Comment Letter.

Form 20-F for Fiscal Year Ended December 31, 2023

Non-GAAP Financial Measures, page 97

Company response: The reconciliation between net income and core operating income for the year has been reported on a net-of-tax basis. Tax adjustments were applied to certain line items arising from the company’s subsidiaries that operate in taxable jurisdictions. The tax impact was calculated by applying the prevailing corporate tax rate of each subsidiary to the gross value of the relevant reconciling items as recognized separately by the subsidiaries on a standalone basis. The related tax impact for the year is immaterial on an individual and aggregate basis for the year ended December 31, 2023.

The Company acknowledges the staff’s comment and confirms that, in future filings, it will separately disclose the tax impact adjustment to the GAAP based amount reported on the face of the financial statements when deriving the non-GAAP tax adjusted amount in the reconciliation, and provide an explanation of how the tax amount was calculated when such amount is material.

B. Liquidity and Capital Resources, page 98

Company response: In future filings, we will include substantially the following disclosure in “Liquidity and Capital Resources” (adjusted with data for the applicable year):

“As of December 31, 2023, our cash and cash equivalents totaled $177.0 million with short-term investments amounting to $42.2 million, providing an available short-term liquidity of $219.2 million. Our entire balance of cash and cash equivalents, as well as our short-term investments, were held by subsidiaries outside the U.S., primarily in Bermuda, the United Kingdom, Malta and Malaysia. These funds are mainly utilized to support the on-going liquidity needs of these subsidiaries outside the United States and, to some extent, to fund the Company’s share repurchase program in the U.S. and dividend distributions in and outside the U.S. by the Bermuda parent company. Since the SEC registrant, which is the parent holding company, is incorporated in Bermuda, and all of its subsidiaries are organized and based outside the U.S., the Company has no need or plans to repatriate cash to the United States. The Company is indefinitely reinvesting its funds held in foreign jurisdictions outside of the U.S. While the Company has no subsidiaries in the United States and no plans to repatriate funds to the U.S., if any of its funds are ever in the future repatriated to the U.S., or used for U.S. operations, certain amounts could be subject to tax. Due to the uncertainty regarding the timing and circumstances of repatriation of any such earnings, if any, it is not practicable at this time to quantify the amount of tax that would be payable in connection with such repatriation.”

Note 2. Summary of Significant Accounting Policies - (k) Deferred policy acquisition costs, page F-13

Company response: As disclosed in Note 2, Summary of Significant Accounting Policies – (k) Deferred policy acquisition costs, the Company does not capitalize the internal costs described in ASC 944-30-25-1A, including salaries, benefits, and other internal underwriting costs.

When the Company first adopted US GAAP effective January 1, 2023, it considered the guidance set forth in ASC 944-30-25-1A, particularly item (d), which provides that: “If the application of the guidance in this paragraph results in the capitalization of acquisition costs that had not previously been capitalized by the insurance entity before fiscal years beginning after December 15, 2011, the insurance entity may elect to not capitalize those types of costs. This election shall be made before fiscal years beginning after December 15, 2011.

In accordance with this provision, the Company conducted a review of its historical accounting practices and determined that it had not previously capitalized the acquisition costs in question (such as salaries, benefits, and internal underwriting costs) prior to fiscal years beginning after December 15, 2011. Consequently, the Company made a one-time accounting policy election, as permitted by the guidance, to continue its existing practice of not capitalizing those types of internal costs.

Based on this, the Company believes that its current accounting policy is consistent with the guidance outlined in ASC 944-30-25-1A.

Note 14. Taxation, page F-40

Company response: In response to the staff’s comment, we will revise future filings to provide further disclosures regarding the Company’s tax structure and strategies, particularly with respect to the allocation of taxable income to jurisdictions like Bermuda with lower or zero tax rates, in contrast to the location of insured risks.

We plan to make substantially the following disclosure in the MD&A in our future filings of Form 20-F:

The Company and its Bermuda subsidiary, International General Insurance Co Ltd. (IGI Bermuda), are not currently subject to any income or capital gains tax in Bermuda.

IGI Bermuda is the Company’s primary underwriting subsidiary and is a Class 3B licensed insurance and reinsurance company regulated by the Bermuda Monetary Authority. As such, a substantial portion of the Company’s gross and net premiums are currently written and earned by IGI Bermuda in Bermuda, where corporate income tax is not currently applicable. IGI Bermuda’s pre-tax income primarily consists of premiums written and earned, net claims and claim expenses incurred, operating expenses incurred, and net realized and unrealized gains(losses) on investments. Given this, a large portion of the Company’s pre-tax income is derived from IGI Bermuda.

The Company also has operations in other jurisdictions where it is subject to income taxes imposed by the respective authorities and is summarized as follows:

The Company’s effective income tax rate, calculated as income tax expense divided by net income before taxes, may fluctuate from period to period based on the geographic distribution of pre-tax income across jurisdictions with different tax rates.

We thank the Staff for its review of the foregoing and the Company’s Form 20-F. If you have further questions or comments, please feel free to contact me at 011 9626 566 2082 Ext. 403 or pervez.rizvi@iginsure.com or our counsel, Michael Levitt, at 212-277 4004 or michael.levitt@freshfields.com

Rawan Alsulaiman

International General Insurance Holdings Ltd.

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