818. Deputy Ged Nash asked the Tánaiste and Minister for Finance the details on the amount of revenue generated for the Exchequer each year since 2016 to 2025 inclusive, under the exit tax charged on investments under the eight year deemed disposal; and if he will make a statement on the matter. [63338/26]

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 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.

Therefore, while it is possible to identify the amounts of tax paid by funds in respect of unit holders, being Investment Undertaking Tax (IUT) and income tax, accounted for by individuals in respect of their investments in Irish domiciled funds and offshore funds, it is not possible to provide a breakdown of the tax which relates to the deemed disposal rule.

On the basis of the information available to Revenue, and based on tax paid over the last eight years, 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, removing the deemed disposal rule could give rise to a potential cost of €284 million. For Budget 2026, an 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 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.