PPLI jurisdictions compared: Singapore, Bermuda, Luxembourg, Liechtenstein, Ireland, Cayman and the US

A PPLI jurisdiction comparison asks one question seven times: if the same private placement life policy were booked here, how would the assets be held, who would rank first if the carrier failed, who could buy it and what reporting would follow? The answers differ mainly in the asset-segregation statute, the policyholder's priority on insolvency and the account's investment rules. Tax follows the client's residence, not the carrier's address.

How to read this comparison

The tables compare legal mechanisms, not carriers or prices. Each cell restates a published statute, regulator page or ruling listed on sources; a dash marks a cell where no primary source has been verified, which never means "no rule". Documents were consulted up to 24 October 2026. Three cautions apply:

1. Statute is not outcome. Whether a segregation rule protects a policy depends on its documents, the timing of funding and the courts involved (asset protection).
2. Eligibility is not suitability. Meeting an accredited-investor test only changes which offers can be made.
3. Hong Kong is outside scope. See insurancehk.si.

Main table: seven jurisdictions on eleven dimensions

A dash (—) means no primary source has been verified; ask the carrier and local counsel. CRS status follows IRAS's List of Participating Jurisdictions (effective 2 February 2026). Solvency II (Directive 2009/138/EC) Art. 275 lets each EEA state give insurance claims precedence over the assets covering technical provisions or over the insurer's assets generally; check the national rule for the carrier concerned.

Reading the table row by row

Regulator, statute and segregation

Luxembourg and Bermuda have the most explicit published segregation mechanisms. In Luxembourg, insurers must keep assets representing insurance liabilities "distinct, and managed separately, from their own assets", with a custodian under a CAA-approved custody agreement (ACA). In Bermuda, a segregated account is "a separate and distinct account" for an identifiable pool of assets and liabilities, and a liability attributable to one account reaches only that account's assets (SAC Act 2000, s.2, s.17 and s.11(4)). Bermuda classes long-term insurers by total assets (Insurance Act 1978); minimum solvency margins are set by BMA rules. Singapore's Insurance Act requires separate insurance funds, including investment-linked funds, but has no custodian triangle. Detail: Luxembourg, Bermuda and Cayman, Singapore.

Priority and protection schemes

Luxembourg's super-privilege ranks policyholders ahead of employees, shareholders, social security institutions and the State; if assets fall short, reimbursements are reduced proportionately (ACA, 2019-02-25). Ireland and Liechtenstein, as EEA states, apply the Solvency II rule that insurance claims take precedence in a winding-up. Liechtenstein's distinctive protection sits on the policyholder side: family beneficiaries can step into the contract when the policyholder's creditors move against it (VersVG Art. 79) — see Liechtenstein and Ireland. Singapore's PPF protects guaranteed benefits only, so it does not reach account values (SDIC).

Eligibility and investment rules

Singapore and the US use investor-level wealth tests; Luxembourg uses policyholder classes to decide which assets may back a policy, under Circular Letter 26/1 for policies concluded from 1 February 2026 and 15/3 before (CMS, 2026-02-09). In the US, the separate account must meet the §817(h) diversification limits set out on US domestic PPLI. See also investment flexibility.

Tests that travel with the client

Full explanation: tax compliance and US domestic PPLI.

PPLI vs PPVA

What the comparison cannot tell you

No table can say which jurisdiction is right for a family. That depends on where family members are tax resident now and later, whether anyone is a US person, which custodians and managers the family uses, the currency of the assets, and the weight given to insurer-insolvency protection against flexibility and cost. Carriers also change through sales and mergers, so check the carrier's current regulator, solvency report and group at application (carriers and custody). For fund vehicles that may sit inside a policy, see vccfund.si.

Tax outcomes depend on the residence of the policyholder, insured and beneficiaries. Obtain advice in each relevant jurisdiction, including Singapore, Hong Kong and mainland China where applicable. If you need help applying this to your situation, you can register an enquiry through the contact options on this site.