It was in previous posts:
1. Regulated funds domiciled within the EU/EEA or any OECD country (including the US) with which Ireland has a Double Taxation Agreement are treated as offshore funds. Gains arising on the disposal of such funds do not qualify for the remittance basis of taxation. This includes (but is not limited to) UCITS authorised investments within these countries.
2. Irish and EU domiciled Exchange Traded Funds (ETF’s) are subject to the offshore fund regime and gains arising on the disposal of such funds do not qualify for the remittance basis of taxation.
3. ETF’s domiciled in the US, and other OECD countries are NOT treated as offshore funds and are subject to mainstream income tax (including USC and PRSI) and capital gains tax. Therefore, the remittance basis is available.
4. Unregulated offshore funds domiciled in the EU/EEA or any OECD country with which Ireland has a Double Taxation Agreement, are subject to mainstream income tax (including USC and PRSI) and capital gains tax. Therefore, the remittance basis is available.
5. Direct investments in foreign/ non-Irish equities are subject to main stream taxes, including income tax (and USC and PRSI) on dividend income and capital gains tax on gains. Therefore, the remittance basis is available.
6. Irish investments (in Irish domiciled funds or Irish equities) should be avoided as any income and gains would not qualify for the remittance basis.