Declaring ETF purchases - what is material interest?

[Innisfree]

Hello all, just a question on declaring ETF purchases.

I understand from other posts on here that people have received conflicting advice on whether Irish-domiciled ETF purchases need to be reported to revenue or not.

While I expect that getting in trouble for not doing it is unlikely, as long as you pay tax on any gain you make. But let's say I want to do so.

My situation was that during 2023 I repeatedly purchased, and sold ETF units (all in VWCE).
I made a total of 21 purchase transactions, where a cumulative total of 1519 units were purchased.
(But - I never held this many at any one point, I sold repeatedly so my total holdings went up and down to zero over the year numerous times, fortunately making a profit each time).

At the end of the year, I only owned 29 units of this ETF, made in 2 transactions in November and December.

So what would you declare to revenue in terms of material interest?

• 29 units across 2 transactions – as that's what my material interest was at year end?
• 1519 units across 21 transactions – as that's what I actually purchased, even though it misleadingly suggests I own a lot more than I really do.
• Nothing - just pay the exit tax on realised gains from the sales during the year and forget about declaring purchases

Thanks in advance for the informed and opinionated opinions!

 

[Corola]

Nothing - just pay the exit tax on realised gains.

Purchases of domestic funds do not need to be declared, only offshore funds. Irish-domiciled funds are domestic, the payments (not purchases) are treated "as if" they were from an offshore fund.

Part 27 - Sections 731-747F

www.revenue.ie

4.2.3 Units held in a recognised clearing system (such as Exchange Traded Funds)

While the fund does not have to deduct exit tax, an Irish resident unit holder will be subject to tax on income and gains arising and must self-assess and include details of income and gains in a timely filing on their income tax return to Revenue.

Section 739G(2)(b) provides that where exit tax is not applied and the unit holder is an individual, the payment is treated as if it is a payment from an offshore fund.

 

[Innisfree]

Thank you, that's helpful to know. I've seen so many conflicting opinions on this.

And I'm sure I read something similar in a Revenue document before, but I just can't find it clearly saying that domestic fund purchases don't need to be declared either.