SecProbe.io

September 17, 2024
Pervez Rizvi
Chief Financial Officer
International General Insurance Holdings Ltd.
74 Abdel Hamid Sharaf Street, P.O. Box 941428
Amman 11194, Jordan
Re:International General Insurance Holdings Ltd.
Form 20-F for Fiscal Year Ended December 31, 2023
File No. 001-39255
Dear Pervez Rizvi:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for Fiscal Year Ended December 31, 2023
Non-GAAP Financial Measures, page 97
1.It appears that certain of your adjustments included in the non-GAAP reconciliation on
page 98 are presented net of tax. If so and if material, please revise future filings to
present the adjustments on a gross basis and present the tax impact in a separate line item
with a clear explanation of how the amount was measured. Please refer to question 102.11
of the C&DIs on Non-GAAP Financial Measures for guidance.
B. Liquidity and Capital Resources, page 98
If significant to an understanding of your liquidity, please revise future filings to clarify
the amount of cash, cash equivalents and short-term investments held by foreign
subsidiaries. Please describe if you must distribute this cash to the U.S. to pay dividends
or to buy back your shares and discuss any other material plans to distribute cash to the
U.S. Also quantify the amount that you consider to be permanently reinvested and may
not be available for distribution to the U.S.  Lastly, please address the potential tax
implications of repatriation or any other material risks. Please provide us your proposed 2.

September 17, 2024
Page 2
revised disclosure.
Note 2. Summary of Significant Accounting Policies - (k) Deferred policy acquisition costs, page
F-13
3.We note your disclosure that you do not capitalize salaries, benefits and other internal
underwriting costs. Please clarify for us if you capitalize the internal costs described in
ASC 944-30-25-1A and, if so, please revise your disclosure in future filings to clarify the
internal costs you capitalize. If not, please tell us how you considered whether your policy
is consistent with the guidance.
Note 14. Taxation, page F-40
4.Please tell us and revise future filings here or in MD&A to discuss the tax structures and
strategies that have resulted in a large portion of your taxable income being allocated to
Bermuda with a 0% tax rate while most of your premiums are related to insured risks
outside of Bermuda as disclosed on page F-52.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Michael Volley at 202-551-3437 or Amit Pande at 202-551-3423 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance