Written answer
Tax Yield
706. Deputy Emer Currie asked the Tánaiste and Minister for Finance the estimated amount raised through deemed disposal taxes in 2026 to date; and if he will make a statement on the matter. [55571/26]
Comment on this
707. Deputy Emer Currie asked the Tánaiste and Minister for Finance the estimated amount raised through deemed disposal taxes in 2025; and if he will make a statement on the matter. [55572/26]
Comment on this
751. Deputy Seán Kyne asked the Tánaiste and Minister for Finance in regard to the deemed disposal rule on electronic funds transfer, if he can provide the total revenue take from this tax in tabular form for the years 2021-2025 inclusive; and if he will make a statement on the matter. [56606/26]
Comment on this
I propose to take Questions Nos. 706, 707 and 751 together.
I propose to answer these PQs together as the Deputies have inquired about the revenue raised through the deemed disposal rule.
The tax revenue arising from the taxation of investment funds and life assurance policies, including the deemed disposal rule, was examined in the context of Budget 2026. The information available to Revenue does not allow them to isolate the tax returned due to the deemed disposal rule from other chargeable events which give rise to a tax liability. Chargeable events include:
• the making of relevant payments;
• the redemption of the investment;
• the transfer by an investor of their investment; and
• the ending of an eight-year period following the acquisition of the investment and then every eight years thereafter (deemed disposal).
Therefore, it is not possible to directly identify the tax revenue arising from the application of the deemed disposal rule. This is because investment funds and life companies are not obliged to report the category of chargeable event that the exit tax relates to at the time of making payment to Revenue. Similarly, as respects investments in certain Irish domiciled funds and offshore funds in respect of which investors are required to self-assess tax due, taxpayers are not required to separately report data for each category of chargeable event when filing their tax return.
For Budget 2026 some costing work was undertaken on the basis of the information available to Revenue, and based on tax paid over the previous eight years. At that time, if it was assumed that 100% of tax paid by funds in respect of unit holders, tax paid by life companies in respect of policy holders, and income tax accounted for by individuals in respect of their investments in Irish domiciled funds, offshore funds and life products, were as a result of the deemed disposal rule, it was estimated that removing the deemed disposal rule could give rise to a potential cost of €284 million. A further estimate was prepared for the Exchequer impact in a year where the deemed disposal rule did not apply, assuming that deemed disposal was closer to 50% of the total tax paid. This assumption results in an estimated full year cost to the Exchequer of €142 million for the removal of the deemed disposal rule for investment funds and life assurance products.
However, it is important to note, that the actual cost could vary where the proportion of tax which arises from deemed disposal rules is higher or lower, as well as where the gains in a particular year are larger or smaller than the eight-year average used for this estimate.
The table below sets out the IUT, LAET, tax on offshore funds and on foreign life policies returned to Revenue from 2021 onward. Please note that for 2025 and 2026 IUT and LAET data is not yet available, nor is the total gross tax liability on income/gains from offshore funds and foreign life policies per the Form 11 return. Form 11 data for 2024 is also not yet available.
* IUT and LAET represent the amount of tax paid to Revenue. It is not possible to identify whether the figures for IUT and LAET represent amounts taxed at 25% in respect of corporate investors or 41% in respect of individual investors.