Gross Roll Up in Funds for Non-Dom

Veronica5

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Is Gross Roll up applied to mutual funds or other types of Funds such as SICAV's for Non - Doms or just to ETF's? What is the date that is taken into account for the 8 year mark? The date it was purchased or the date you became Irish tax Resident? For example, if I have invested in a long term fund or ETF since 2007 and I became a Non-Dom Irish Tax Resident in 2020, am I liable for Gross Roll Up?
 
We just had this exact situation with a client.

When moving to Ireland the advice is always to rebase any investments prior to becoming Irish tax resident.

Where you don’t do this then any investment that you hold now fall under Irish tax principles.

A UCITS fund does not qualify for remittance taxation. Therefore the gross roll up rules apply.

You are therefore liable to exit tax on the unrealised gains every 8 years even if you don’t dispose of the investment.

The gain in this instance is calculated as the notional value above the original purchase.

This hardly seems fair since you purchased when not Irish tax resident and this is why it’s so important when moving to Ireland to sell before becoming tax resident.

In these circumstances we generally advise that if you intend to remain in Ireland for a reasonable time that you should dispose of these investments and start again with a more suitable investment which does qualify for remittance tax.

We frequently see U.K. clients in particular move to Ireland and fail to dispose of their tax free ISAs before becoming tax resident and then get cross when they discover these are wholly taxable in Ireland.

It happens all the time

 
Thank you so much Mark!! I see you have ad advising firm. I'm going to contact you as I may need your assistance. Kindest regards.
 
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