The Irish Tax Regime
For more than a quarter of a century, Ireland has been a leading regulated domicile for internationally distributed investment funds. The Irish tax regime has been, and continues to be, one of the key growth drivers of the funds industry in Ireland.
“Ireland’s tax neutral regime for globally distributed investment funds has been in place for over 25 years.”
Ireland for Tax Transparency and Best Practice
Ireland’s tax regime, as well as being highly efficient, clear and certain, is open, transparent and fully compliant with OECD guidelines and EU law. The Irish framework is legislation-based and does not rely on rulings. Ireland has been credited with:
- Having the highest rating in the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes.
- Being the first international fund domicile to sign an Intergovernmental Agreement (IGA) with the US in respect of the implementation of FATCA.
- Being an early adopter jurisdiction of the OECD’s Common Reporting Standard (CRS) regime.
Ireland is guiding best practice in international tax developments and this demonstrates Ireland’s commitment to international tax transparency and administrative co-operation. This commitment is vital to protecting Ireland’s reputation as a responsible, regulated, on-shore jurisdiction and ensuring Ireland’s tax neutral regime facilitates tax efficient investments.
Tax Implications for Funds
Irish regulated funds are exempt from Irish tax on income and gains derived from their investments and are not subject to any Irish tax on their net asset value. There are additionally no net asset, transfer or capital taxes on the issue, transfer or redemption of units owned by non-Irish resident investors.
Tax Implications for Investors
Other than in respect of certain funds which hold interests in Irish real estate (or particular types of Irish real estate related assets), non-Irish investors are not subject to Irish tax on their investment and do not incur any withholding taxes on payments from the fund.
As provided under EU law, the provision of management, administration and custody services to an Irish regulated fund is exempt from Irish VAT. Other services, such as legal and accounting services, can result in an Irish VAT liability, but may be offset, depending on the fund’s VAT recovery position.
Tax Treaty Network
Spanning over 70 countries across the EU, Middle East, Asia and South America, Ireland has one of the most developed and favourable tax treaty networks in the world. The availability of treaty benefits in a particular case will ultimately depend on the relevant tax treaty and the approach of the tax authorities in the treaty country. Consequently, treaty access needs to be reviewed on a case-by-case basis. View the full list tax treaties networks on the Irish Revenue website.
Please note that this site is not intended to answer questions about individual investments nor is it intended to give professional or legal advice. Please see our disclaimer.