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MSL Business SchoolGeneral insurance, life insurance and policy proceeds

Ghana Insurance Business Tax

The special Act 896 computations for general and life insurance, the policyholder rules and the separate VAT and withholding layers affecting insurance transactions.

Published by MSL Business School.

Primary lawIncome Tax Act, 2015 (Act 896), sections 89–92; Value Added Tax Act, 2025 (Act 1151); Act 915CoverageGeneral insurance, life insurance, reinsurance, reserves, claims, policyholder proceeds, VAT and withholdingCurrent-law statusReviewed Institutional publisherMSL Business School

MSL Business School — General insurance, life insurance and policy proceeds at a glance

01Separate businessInsurance and other activities are computed separately
02General insurancePremiums, claims, reinsurance and unexpired-risk reserve
03Life insurancePremium and policy-payment flows are excluded from income computation
04Resident insurerPolicyholder life-insurance gain is exempt

Controlling answer

General and life insurance use different income-tax computations.

A person conducting insurance must compute the insurance activity separately from other business. General insurance brings premiums and relevant reinsurance proceeds into income and permits specified claims, reinsurance premiums and the year-end unexpired-risk reserve. Life insurance excludes the premium and policy-payment flows specified in section 90, while the insurer's other income and expenses remain within the ordinary computation.

General insurance, life insurance and policy proceeds

General insurance follows a premium, claims and reserve computation

General-insurance itemSection 89 treatment
Premiums earned as insurer or reinsurerIncluded in business income for the year.
Reinsurance proceeds relating to insured claimsIncluded in income.
Claims incurred as insurer or reinsurerDeductible subject to section 8 and the incurred-claim conditions.
Reinsurance premiums relating to those claimsDeductible under the special computation.
Reserve for unexpired risk at year endDeductible under section 89(3).

For the incurred-claim rule, the events determining liability must have occurred and the amount must be deductible in accordance with generally accepted accounting principles. A general provision is not automatically the statutory deduction.

General insurance, life insurance and policy proceeds

Life-insurance premium and policy-payment flows are removed from the income base

Section 90 requires the life-insurance business and any other business activity to be computed separately. In the life-business computation:

Excluded from income

Premiums received as insurer or reinsurer and reinsurance proceeds related to policy proceeds are excluded and do not become consideration for an asset or liability.

Not deducted

Policy proceeds incurred as insurer or reinsurer and the related reinsurance premiums are not deducted and do not enter the cost of an asset or liability.

Ordinary income remains

Investment and other income not removed by section 90 remains subject to the Act's ordinary rules, with qualifying deductions and financial-accounting evidence.

This statutory symmetry prevents the core premium-and-policy-payment flows from distorting the life insurer's taxable result.

General insurance, life insurance and policy proceeds

The insurer's residence controls the life-policy gain rule

Payment to insured personIncome-tax result for the insured
Life-insurance proceeds paid by a resident insurerThe gain is exempt.
Life-insurance proceeds paid by a non-resident insurerThe gain is included in the insured person's income.

For this rule, the gain is the amount by which the life-insurance proceeds exceed the premiums paid to that insurer for the policy. The full proceeds are not automatically the gain.

Classification matters: section 92 defines life insurance for this division. Test the policy terms rather than relying only on the product name.

General insurance, life insurance and policy proceeds

Income tax, VAT and withholding are separate layers

VAT

Act 1151 is the current VAT law from 1 January 2026. A taxable insurance supply uses the current 15% VAT, 2.5% NHIL and 2.5% GETFund architecture, subject to the Act's exemptions and input-credit conditions.

Policy claims

A claim payment is not treated as consideration for a taxable supply merely because the premium was taxable. Analyse recoveries, salvage and service inputs separately.

Non-resident general-insurance premium

The domestic withholding schedule includes a 5% rate on a general-insurance premium paid to a non-resident insurer, before any valid treaty or statutory modification.

Commissions and services

Insurance commissions and other service payments may attract withholding according to the recipient, residence and payment category.

General insurance, life insurance and policy proceeds

Reconcile regulatory accounts to every tax base

  1. 01
    Separate business ledgers

    Keep general insurance, life insurance and other activities distinct.

  2. 02
    Reconcile premiums and reinsurance

    Bridge policy systems to the general ledger, VAT records and income-tax computation.

  3. 03
    Evidence claims and reserves

    Keep occurrence dates, notifications, actuarial or claims support, payments, recoveries and accounting treatment.

  4. 04
    Map policyholder products

    Identify which contracts meet the Act 896 life-insurance definition and which VAT treatment applies.

  5. 05
    Test separate levies

    Confirm whether the Growth and Sustainability Levy or another sector levy applies to the insurer and reconcile its distinct base.

  6. 06
    File each return on its own timetable

    Income tax, VAT, withholding, PAYE and any sector levy remain separate obligations.

Frequently asked questions

Ghana Insurance Business Tax questions

Are general and life insurance taxed the same way in Ghana?

No. Sections 89 and 90 prescribe different computations.

Is an unexpired-risk reserve deductible for general insurance?

Section 89 permits the amount of the reserve for unexpired risk at the end of the basis period in the special general-insurance computation.

Are life-insurance premiums included in a life insurer's taxable income?

The premiums specified in section 90 are excluded from income under the life-business computation.

Is a policyholder's life-insurance gain taxable?

A gain paid by a resident insurer is exempt; a gain paid by a non-resident insurer is included in income.

Does insurance income tax replace VAT?

No. Income tax, VAT, withholding and any sector levy are separate layers.

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TaxLawGH is MSL Business School's Ghana tax education platform.

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