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CONFIDENTIAL
TREATMENT REQUESTED BY INTERNATIONAL GENERAL INSURANCE HOLDINGS LTD. PURSUANT TO 17 C.F.R. §200.83

January 17, 2020

VIA
EDGAR

U.S.
Securities & Exchange Commission

Division
of Corporation Finance

Office
of Energy & Transportation

100
F Street, NE

Washington,
D.C. 20549

Attn:
 David Gessert and Michael Clampitt

    Re:

    International
        General Insurance Holdings Ltd.

        Registration
        Statement on Form F-4

        Filed
        December 9, 2019

        File
        No. 333-235427

    CERTAIN PORTIONS OF THIS LETTER AS FILED VIA EDGAR HAVE BEEN OMITTED AND PROVIDED TO THE DIVISION OF CORPORATION FINANCE. CONFIDENTIAL TREATMENT HAS BEEN REQUESTED WITH RESPECT TO THE OMITTED PORTIONS. OMITTED INFORMATION HAS BEEN REPLACED IN THIS LETTER AS FILED VIA EDGAR WITH A PLACEHOLDER IDENTIFIED BY THE MARK “[***].”

Dear
Messrs. Gessert and Clampitt:

International
General Insurance Holdings Ltd. (the “Company” or “we”) hereby transmits its response to
the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission, dated
January 6, 2020, regarding the Company’s Registration Statement on Form F-4 which was filed on December 9, 2019 (the “Registration
Statement”). For the Staff’s convenience, we have repeated below the Staff’s comments in bold, and have
followed each comment with the Company’s response.

Registration
Statement on Form F-4

Cover
Page

 1. We
                                         note in the letter to the stockholders of Tiberius Acquisition Corporation that Proposal
                                         1 asks shareholders to both (i) approve the Business Combination Agreement and (ii) adopt
                                         the Amended and Restated Pubco Bye-laws. Please revise to unbundle and state separately
                                         these two matters to be acted upon or tell us why they are not required to be stated
                                         separately. Refer to Exchange Act Rule 14a-4(a)(3) for guidance.

The
Company acknowledges the Staff’s comment. We understand the Staff’s views regarding the unbundling of a bye-law amendment
from a business combination proposal, and appreciate that a registrant may not circumvent a separate vote on proposals by merely
creating a new entity and effecting amendments by means of a merger. However, we believe that the circumstances relating to the
Tiberius/IGI business combination are distinguishable from the foregoing, for the following reasons, and that the approval of
the Business Combination Agreement and of the Amended and Restated Pubco Bye-laws are not required to be stated separately:

    ●
    Unbundling
    represents, as we understand, an effort to assure that shareholders have a vote on each material change sought to be made
    to the bye-laws, with the bye-laws as adopted being based on the results of each individual vote.  However, providing
    for a separate vote with respect to Pubco’s bye-laws would, we believe, serve no useful purpose, insofar as the
    shareholders     of Tiberius will be voting on the business combination itself, and the failure to separately approve any
    proposed change to     the bye-laws would be contrary to the terms of the Business Combination Agreement and result in the
    failure to close the business     combination (even if the shareholders have separately approved the business combination).
    Each of the aspects of the business     combination is therefore part of the business combination vote, including not only
    accepting the Pubco bye-law provisions,     but also the valuation and exchange ratios associated with the business
    combination, the terms and timing of payments to the     sellers, the corporate structure of Pubco following the business
    combination, the change of control to be effected by the     business combination, and the identity of the directors and
    management of Pubco going forward.  Most significantly, the     business combination will involve a decision by Tiberius
    shareholders to cease to be a special purpose acquisition company     and instead to become an operating company engaged in
    the business activities in which IGI is currently engaged. The     transaction is more in the nature of a sale of
    Tiberius to a third party (the IGI shareholders) than a reorganization solely     within the control of Tiberius.

    [***] = Certain confidential information contained in this document, marked by brackets, has been omitted
 and filed separately with the Securities and Exchange Commission pursuant to 17 C.F.R. §200.83.

    U.S. Securities and Exchange Commission
 January 17, 2020
 Page 2

    ●
    The
    Pubco amended and restated bye-laws are set forth as an appendix to the Business Combination Agreement and constitute a part
    of such agreement.  Therefore, the vote to approve the Business Combination Agreement inherently involves a vote
    on the Pubco amended and restated bye-laws, among other things.

    ●
    The
    organization of Pubco, including its bye-law provisions, was not solely within the discretion of Tiberius, but was integral
    to the overall negotiations between Tiberius, IGI and the other parties to the Business Combination Agreement. The provisions
    of the Pubco bye-laws reflect the basis upon which IGI intends to operate following the business combination. We note that,
    following the business combination, the current shareholders of IGI, and not the shareholders of Tiberius, will control Pubco.

    ●
    If there are to be any changes to Pubco’s bye-laws, under Bermuda law, the only parties who have
the authority to effect such amendments before the consummation of the business combination are the current Pubco board of directors
together with the Pubco shareholders. Prior to the business combination, the Tiberius shareholders have no legal ability to vote
to amend Pubco’s bye-laws.

For
the above reasons, the Company respectfully submits that the request by the Staff that there be a separate vote by the Tiberius
shareholders on the Pubco bye-laws should not be applicable to the proposed transaction.

 2. We
                                         note that several of the proposals you are submitting for shareholder action are conditioned
                                         upon shareholder approval of the Business Combination Proposal. Please revise the narrative
                                         following the summary of the proposals to disclose whether the Business Combination is
                                         conditioned upon shareholder approval of any of the other proposals. If it is not then
                                         please explain what will happen if the Business Combination Proposal is approved but
                                         Proposal 3, the Share Issuance Proposal, is not.

In
response to the Staff’s comment, we have revised the Registration Statement to disclose that the Business Combination is
conditioned upon the shareholder approval of each of the Incentive Compensation Plan Proposal and the Share Issuance Proposal.
The revised disclosure can be found in the notice of special meeting following the summary of the proposals and on pages 10, 23, 156 and 157 of the Registration Statement.

 3. Please
                                         revise to provide a cross reference to the risk factors section that conforms to the
                                         requirements of Item 501(b)(5) of Regulation S-K.

In
response to the Staff’s comment, we have revised the Registration Statement to add a more complete cross reference to the
risk factors section thereof pursuant to the requirements of Item 501(b)(5) of Regulation S-K. The revised disclosure can be found
on the cover page of the proxy statement/prospectus.

    [***] = Certain confidential information contained in this document, marked by brackets, has been omitted
 and filed separately with the Securities and Exchange Commission pursuant to 17 C.F.R. §200.83.

    U.S. Securities and Exchange Commission
 January 17, 2020
 Page 3

 4. Please
                                         disclose on the Proxy Statement/Prospectus cover page that concurrent with this offering
                                         Pubco will issue 28,372,900 of its common shares to holders of IGI common stock under
                                         Regulation S that are not being registered here.

In
response to the Staff’s comment, we have revised the Registration Statement to disclose that, concurrent with the offering
of Pubco securities that are being registered therein, Pubco will issue 28,372,900 of its common shares to holders of IGI common
stock in reliance upon an exemption from registration provided by Regulation S promulgated under the Securities Act of 1933, as
amended. The revised disclosure can be found on the cover page of the proxy statement/prospectus.

Summary
of the Material Terms of the Business Combination, page 7

 5. We
                                         note your disclosure in the first paragraph on page 8 that Pubco common shares equal
                                         to 2.5% of the total Transaction Consideration will be issued in the name of the Sellers
                                         but will be set aside in escrow at the Closing to be used as the sole source of remedy
                                         available to Pubco for any post-closing negative adjustments to the total Transaction
                                         Consideration. Briefly describe the circumstances that could give rise to any post-closing
                                         negative adjustments and explain how such adjustments could affect total Transaction
                                         Consideration.

We
respectfully advise the Staff that the post-closing Transaction Consideration adjustments are described under “The Business
Combination Proposal - The Business Combination Agreement and Related Agreements – General Terms, Effects and Consideration”
of the Registration Statement.  The Transaction Consideration is equal to (i) the sum of (A) the total consolidated book
equity value of IGI and its subsidiaries as of the most recent month end of IGI prior to the closing of the business combination
(the “Book Value”), plus (B) the IGI transaction expenses that reduced Book Value, multiplied by (ii) 1.22, and multiplied
by (iii) the percentage of IGI shareholders that agree to exchange their shares.  The Book Value and IGI transaction expenses
will be estimated at the closing of the business combination (since the full financial statements for the most recent month end
prior to the closing may not have been prepared as of the closing) and subject to a post-closing true-up.  If the finally
determined Book Value, net of IGI transaction expenses that reduced Book Value, is less than the Book Value which was estimated
at closing, net of IGI transaction expenses that reduced Book Value, then there would be a negative adjustment. The maximum number
of shares which the IGI shareholders would forego in the event of a negative adjustment is 900,710 (based on IGI’s book
value as of June 30, 2019, estimating the redemption price of Tiberius common stock in March 2020 and assuming no redemptions
by Tiberius shareholders).

We
have revised the Registration Statement to describe the foregoing in the section entitled “Summary of the Material Terms
of the Business Combination”. The revised disclosure can be found on page 7 of the Registration Statement.

Risk
Factors

Risks
Relating to the Business and Operations of IGI

The
exit of the United Kingdom from the European Union could have a material adverse effect on IGI’s business, page 82

 6. Please
                                         expand this risk factor to describe the magnitude and relative importance of IGI's UK
                                         operations. In this regard, we note your disclosure under Business of IGI on page 175
                                         related to GWP by geography.

In
response to the Staff’s comment, the Company has revised the disclosure on page 82 of the Registration Statement.

    [***] = Certain confidential information contained in this document, marked by brackets, has been omitted
 and filed separately with the Securities and Exchange Commission pursuant to 17 C.F.R. §200.83.

    U.S. Securities and Exchange Commission
 January 17, 2020
 Page 4

The
Business Combination Proposal

The
Business Combination Agreement and Related Agreements- Illustration of Transaction

Consideration
and Post-Closing Pubco Ownership, page 95

 7. Please
                                         revise to include a table illustrating, pursuant to the Business Combination Agreement,
                                         the per share consideration that will be paid for each share of Tiberius and IGI common
                                         stock, respectfully, that is exchanged. For shares of IGI common stock exchanged, show
                                         the value of the consideration paid per share for shares exchanged for equity consideration
                                         and those exchanged for cash consideration separately.

In
response to the Staff’s comment, the Company has revised the disclosure on page 96 of the Registration Statement.

Background
of the Business Combination, page 104

 8. We
                                         note your disclosure on page 110 that transaction terms related to “enhanced economics
                                         for IGI shareholders” were discussed on April 1, 2019. Please expand your disclosure
                                         to describe the nature of the terms that were discussed.

In
response to the Staff’s comment, we have expanded the disclosure to describe the nature of the terms that were discussed
by the parties on April 1, 2019. The revised disclosure can be found on page 110 of the Registration Statement.

Tiberius
Board of Directors’ Reasons for the Approval of the Business Combination, page 116

 9. We
                                         note your disclosure that the comparable transactions you reviewed in determining the
                                         IGI acquisition price-to-book multiple of 1.22x equaled on average 2.30x book value.
                                         Please expand your disclosure to provide the respective price-to-book multiple for each
                                         comparable company you have listed.

In
response to the Staff’s comment, we have added a table that shows the respective price-to-book multiple for each comparable
company listed in the Registration Statement. The revised disclosure can be found on page 116 of the Registration Statement.

Unaudited
Pro Forma Combined Financial Statements

Accounting
for the Business Combination, page 144

 10. Your
                                         statement here that you present the net assets of Tiberius Acquisition Corporation acquired
                                         at historical cost is inconsistent with that in the first paragraphs on pages 27 and
                                         142. Please address the following:

 ● Tell
                                         us why it is appropriate to reflect the net assets of Tiberius at historical cost in
                                         your pro forma financial statements and in your anticipated post-merger financial statements.
                                         Reference for us the authoritative literature you rely upon to support your position
                                         specifically indicating how your accounting complies with IFRS 3.1