Mass. Gen. Laws ch. 63 § 23
Every foreign insurance company coming within the scope of the definition of a foreign company in section 1 of chapter 175, except life insurance companies with respect to business taxable under sections 20 and 21 and marine, or fire and marine, insurance companies with respect to business taxable under section 29A, shall annually pay an excise upon the gross premiums for all policies written or renewed, all additional premiums charged, and all assessments made during the preceding calendar year for insurance of property or interests in this commonwealth, or which are subjects of insurance by contracts issued through companies or agents therein, exclusive of reinsurance, at the rate of 2.28 per cent but not less in amount than would be imposed by the laws of the state or country under which such company is organized upon a like insurance company incorporated in this commonwealth, or upon its agents, if doing business to the same extent in such state or country.
Mass. Gen. Laws ch. 63, § 23