Chubb Limited: 10-K Risk Factor Changes

Chubb Limited and our non-U.S. subsidiaries operate such that none of these companies should be subject to U.S. tax (other than U.S. excise tax on insurance and reinsurance premium income attributable to insuring or reinsuring U.S. risks and U.S. withholding tax on some types of U.S. source investment income), because none of these companies should be treated as engaged in a trade or business within the U.S. However, because there is considerable uncertainty as to the activities that constitute being engaged in a trade or business within the U.S., we cannot be certain that the Internal Revenue Service (IRS) will not contend successfully that Chubb Limited or its non-U.S. subsidiaries are engaged in a trade or business in the U.S. If Chubb Limited or any of its non-U.S. subsidiaries were considered to be engaged in a trade or business in the U.S., such entity could be subject to U.S. corporate income and branch profits taxes on the portion of its earnings effectively connected to such U.S. business, in which case our results of operations and our shareholders' equity could be adversely affected.

Chubb Limited and our non-U.S. subsidiaries operate such that none of these companies should be subject to U.S. tax (other than U.S. excise tax on insurance and reinsurance premium income attributable to insuring or reinsuring U.S. risks and U.S. withholding tax on some types of U.S. source investment income), because none of these companies should be treated as engaged in a trade or business within the U.S. However, because there is considerable uncertainty as to the activities that constitute being engaged in a trade or business within the U.S., we cannot be certain that the Internal Revenue Service (IRS) will not contend successfully that Chubb Limited or its non-U.S. subsidiaries are engaged in a trade or business in the U.S. If Chubb Limited or any of its non-U.S. subsidiaries were considered to be engaged in a trade or business in the U.S., such entity could be subject to U.S. corporate income and branch profits taxes on the portion of its earnings effectively connected to such U.S. business, in which case our results of operations and our shareholders' equity could be adversely affected. Historically, our Bermuda operations have not been subject to Bermuda income tax. However, on December 27, 2023, the Government of Bermuda enacted a 15 percent income tax effective January 1, 2025. The new Bermuda income tax will be a covered tax under the OECD’s global minimum tax regime discussed in our Risk Factor below titled “The Organization for Economic Cooperation and Development (OECD), European Union (EU), Swiss Federal Council, and other jurisdictions are considering, have considered, or have passed measures that might change long standing tax principles that could increase our taxes.” Therefore, we would expect any implementation of the OECD global minimum tax regime to count any current Bermuda income tax toward such OECD minimum tax. The imposition of the Bermuda corporate income tax will increase our effective tax rate and cash taxes paid beginning in 2025.

The OECD has published a framework for taxation that in many respects is different than long standing international tax principles. This framework, along with related Administrative Guidance, is redefining what income is taxed in which country and instituted a 15 percent global minimum tax in 2024 or later years. To date, the EU and many other countries have enacted the 15 percent global minimum tax. Switzerland has enacted aspects of these rules, effective on January 1, 2025, including the income inclusion rule. On January 15, 2025, the OECD issued Administrative Guidance that, if incorporated into law, could cause additional tax to be payable to the extent the deferred tax asset we established upon enactment of Bermuda’s corporate income tax in 2023 reverses after 2026. It is uncertain at this time whether and to what extent the jurisdictions in which we operate will implement this guidance.

The OECD has published a framework for taxation that in many respects is different than long standing international tax principles. This framework, along with related administrative guidance, could redefine what income is taxed in which country and institute a 15 percent global minimum tax in 2024 or later years. To date, many EU and other countries have enacted the 15 percent global minimum tax. Switzerland has enacted aspects of these rules, effective on January 1, 2025, including the income inclusion rule but not the under taxed profits rule. 31 31 31 Table of Contents Table of Contents On January 15, 2025, the OECD issued administrative guidance that, if incorporated into law, could cause additional tax to be payable to the extent the deferred tax asset we established upon enactment of Bermuda’s corporate income tax in 2023 reverses after 2026. It is uncertain at this time whether and to what extent the jurisdictions in which we operate will implement this guidance. On January 20, 2025, President Trump issued a memorandum announcing that the OECD framework has “no force or effect in the United States” and disavowing any commitments previously made by the United States with respect to the framework. The memorandum also directs the U.S. Secretary of the Treasury to develop and present to President Trump a list of protective measures or other options towards foreign countries that are either not in compliance with any tax treaty with the United States or have tax rules that are “extraterritorial or disproportionately affect American companies.” The possible uneven enactment of the OECD framework by various jurisdictions coupled with the United States’ response to these rules could cause uncertainties to and increases in our income taxes. Several multilateral organizations, including the EU and the OECD have, in recent years, expressed concern about some countries not participating in adequate tax information exchange arrangements and have threatened those that do not agree to cooperate with punitive sanctions by member countries. It is still unclear what all these sanctions might be, which countries might adopt them, and when or if they might be imposed. We cannot provide assurance that the Tax Information Exchange Agreements (TIEAs) that have been entered into by Switzerland and Bermuda will be sufficient to preclude the sanctions described above, which, if ultimately adopted, could adversely affect us.