Submission to Minister for Finance on SIAs

Brendan Burgess

Founder
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I have sent off my submission this morning. Thanks for all the input. I have cut and pasted it from the Word document, so the formatting here is a bit upset. But the actual Word document is well laid out.


The Consumer Forum – Askaboutmoney.com

​
16th March 2026

Mr Simon Harris
Minister for Finance
Department of Finance
By email to minister@finance.gov.ie

Dear Minister

As we do not have a functioning advocacy body representing savers or investors in Ireland, I would like to make a submission on behalf of savers and investors. I host the consumer forum askaboutmoney.com where these issues are frequently discussed. The issue is also discussed by savers and investors on other forums so this submission summarises the combined wisdom of the contributors. It is not the official position of askaboutmoney, as we don’t have one. Individual contributors have their own opinions.

The banking and insurance industry are very good at advocating for their own interests which may not be aligned with the interests of the consumer. Therefore, it is important that the consumer voice be heard.
I attach my submission and would be happy to attend any meetings with you or your officials on the issue.

Yours sincerely



Brendan Burgess
Founder - askaboutmoney.com


Submission on proposed Special Investment Accounts​

Compiled by Brendan Burgess based on discussions on Askaboutmoney.com and other online savings and investments forums.
13th March 2026

Part 1 Removing the inequities in the present taxation regime​


As part of the introduction of any new product, the current regime should be reformed.

It is better for most investors to invest in collective funds which hold a diversified range of investments. Direct investment in shares exposes the investor to stock-specific risk. However, the current tax regime strongly favours investing directly in shares over investing through collective funds.



Direct investment in sharesInvestment through a collective fund
Unrealised capital gains are not taxed
Dividend income is taxed every year at the marginal rate – usually 50%
A capital loss on one asset can be set off against a gain on another.
Capital gains disappear on death and are not taxed
Unrealised gains are taxed every 8 years
Income is taxed every 8 years at 38%


A capital loss on one fund cannot be set off against gains elsewhere
Exit tax is payable on death

There is no justification for such a disparity in the tax treatment of what is essentially the same income and capital gains.
Collective investments ( ETFs, Life company funds, UCITS) should all be subject to the same Income Tax and Capital Gains Tax regime as direct investment in shares. Investors should pay Income Tax on any income they receive and Capital Gains Tax on any gains they realise as they do with direct investment in shares. A loss on any investment product should be allowed to be offset against a gain on any other product or asset.

Deemed Disposal and the Exit Tax should be abolished.

The level of Income Tax paid would depend on the tax status of the individual which would result in a fairer, more progressive tax system. People would pay taxes at their marginal rate. For a pensioner on low income this could be 0%, while for a higher rate taxpayer it would be about 50%.

Some argue that taxing accumulating funds on realised gains only would give such investors a big advantage as income would not be taxed annually and could be rolled up and eventually be subject to CGT instead of Income Tax. This could be dealt with by applying the Income Tax and CGT regime to only those funds which distribute at least 85% of their income. A precedent exists for this in the REITS regime. Funds which accumulate income could remain subject to deemed disposal and Exit Tax. While this might be seen as more equitable, it would effectively restrict Irish investors to a limited range of distributing funds and maybe the level of inequity would not justify this restriction.


Part 2 A Special Investment Account for smaller savers and investors


You should be very clear on what the objectives of any such SIA are

These objectives will determine what the best model for any new product is.

Long-term savers should be encouraged to move their savings into higher yielding products.


What would make the SIA attractive to ordinary savers and investors?


  • Flexibility in terms of variable contributions and withdrawals

  • No minimum contribution period or holding period

  • Simplicity – investors are more likely to invest in something they understand

  • No Income Tax or Capital Gains Tax within the fund.

  • No Exit Tax on withdrawals.

  • Exemption from having to make a tax return

  • Low charges


Contribution levels and fund size

As the primary objective of any new SIA is to encourage people to move their savings from deposit accounts to more productive accounts, the quickest way to achieve this would be to set a maximum contribution limit which could be achieved immediately through a one-off contribution or which could be built up over time.

If the contribution limit is set at €1,000 per month, it will take a very long time to achieve the objective of moving a significant amount of deposits into higher yielding products. On the other hand, if the maximum contribution is set at €100,000 without any time constraint , an investor could contribute that in one payment now. An investor who has €30,000 to invest could contribute that as a one-off payment, and if their finances subsequently allow, they could contribute up to a further €70,000.

In any event, a “use it or lost it” limit should be avoided. The SSIA had a maximum monthly contribution limit. If a person did not contribute the maximum one month, they could not make up the shortfall in later months. This “use it or lose it” unfairly favours wealthy investors and should be avoided.

Investors who need to withdraw money from the fund should be allowed to subsequently reinvest it when their financial circumstances allow. An investor may need to withdraw the money during a period of unemployment or for some other reason. The door should not be closed after them. They should be allowed to put back the amount they withdrew.

There should not be a minimum holding period. There is no justification for such a restriction and it makes the product more complex and much less attractive.




Ideally the fund should be completely free of tax and the need to make tax returns

The fund should be exempt from taxes on income and on capital gains. When the fund is cashed, there should be no tax liability on the increase in value.

If this is considered too generous, then the tax should be deducted by the fund manager on encashment and the investor should have no further tax liability and no obligation to make a tax return.

What will the new product be allowed to invest in?

The new products should not be limited to investing in the Irish economy or in Irish SMEs though, of course, they would be free to do so. The SIA should be allowed to invest in bank deposits, shares, fixed-income securities, ETFs or any collective investments which can legally be marketed to Irish investors.

Will the SIA allow the holding of deposit accounts?

On the one hand the SIA should encourage long term investors to move from low-yielding deposit accounts to higher yielding products like equities. But on the other hand, deposit accounts are the most suitable vehicle for younger people saving up for a deposit on a house. It would seem unfair to give a tax break to mortgage-free homeowners who have spare funds to invest in equities while taxing younger people saving up to get on the housing ladder.

The interaction with pensions needs to be considered

A pension fund should be the main vehicle for long term savings.

A younger person might see an SIA as more attractive as they could access the money earlier. Furthermore, if their marginal tax rate is 20%, they may be better off saving through an SIA and then withdrawing it when their tax rate rises to 40%.

Lower earners generally will favour the SIA over pensions, as they are more likely to need to access savings in an emergency.

The potential impact on mortgage rates should be considered

At the end of 2025, Irish households had €152 billion on deposit in Irish banks while €93 billion was lent out in mortgages. If the SIA results in, say, €20 billion of deposits moving to equity funds, the ability of the Irish banks to provide mortgages will not be impacted. However, if the SIA is more successful than anticipated, it could result in Irish banks using it as an excuse to increase mortgage rates.

How the UK ISA meets the suggested features


The UK ISA allows the investor to invest up to £20,000 a year in equities or cash.


  • Many would consider £20,000 a year too generous as it has resulted in over 5,000 ISA millionaires

  • At this level of contribution, young people may see this as a better way to save than contributing to a pension

  • It is a "use it or lose it" system, so only very wealthy people can afford to make the maximum contribution

  • Once money is taken out, it can't be put back in


How the Canadian Tax-free Savings Account meets the recommended features

The Canadian Tax-free Savings Account is an interesting model. It has an accumulating limit of the equivalent of €4,000 per annum. Each year from age 18, the person builds up an accumulating capacity of €4,000. So, someone who has made no contributions in 10 years, can contribute up to €40,000. If they subsequently withdraw €20,000, when they are next in a position to contribute that amount, they can do so.

There is no Income Tax or Capital Gains Tax within the Account

This is a very good model but allowing depositors to move only €4,000 a year starting now, would take a long time to achieve the objective of moving large amounts from deposit accounts into higher yielding investments. That is why a total limit of say, €100,000 which would apply immediately is more likely to achieve the objectives of the SIA.

How the Swedish ISK meets these criteria

In simple terms, this is a wealth tax of 1% on the value of the investment instead of Income Tax and CGT. But no wealth tax is imposed on the first €30,000 of investments.

This is very simple and easy to understand. It is very flexible. There is no requirement to make a tax return.
Another big advantage of the Swedish ISK is that there is no need for different systems for larger and smaller investors. One size actually does fit all.

After €30,000, everyone pays the same rate irrespective of their income or wealth. So, a person with low income but high investments pays 1% even if they have no taxable income while a top rate taxpayer, also pays 1%. While this has the merit of simplicity, some would argue that a progressive rate would be fairer e.g. 0.5% on the first €100,000 and 1% thereafter.

References and further information
The evolution of this submission can be seen in the following discussions:
First draft of submission
Second draft of submission
Final version
The Canadian Tax Free Savings Account as a model for an Irish ISA?
The Swedish equivalent of an ISA as a model for Ireland?
The UK ISA as a model for an Irish product?
Should the new SIA be allowed to hold deposits?
Would the proposed Special Investment Account impact on mortgage rates?
 
Well done Boss. A slight technical correction though. Someone has pointed out that in fact it is the Swedish punter who is required to pay the tax through their tax returns. That is of course not essential to the system - a key recommendation if ISK is adopted should be that the provider pays the tax as as a final settlement.
 
Glad that you are there. Curious as to how you got there. probably invited because you made submission.
Fearful that Industry will hijack the accounts to their benefit.
Should be no annual or total limits
Have dug out all on ISK in Sweden.
 
a key recommendation if ISK is adopted should be that the provider pays the tax as as a final settlement.
Not if they will charge 25bps for it!!

Some other posters mentioned DEGIRO etc. supporting ISKs. If we push the providers too hard we might scare away the low fee platforms.
 
There was very little detail and they will be consulting on it.

The minister set out 4 principles

1) A flat rate of tax above a tax-free threshold
2) No other tax
3) "All investments consistent with..." sorry can't read my notes
4) the provider does the admin.

Any system should be
  • Simple
  • Clear
  • Accessible
They are working on the legislation and they want it ready to go in early 2027.

There will be a broader rethink of the taxation of investments

Fair play to him. He actually stayed for all the speakers so from about 9.30 to 11.30.
After the coffee break, his Junior Minister arrived to listen to the panel discussion and further comments from the floor.
 
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I made the following points from the floor:

He should add a first principle of fairness. It is unfair to give someone who has cleared their mortgage and has spare cash to invest a tax break, while taxing those who are saving in a deposit account to get on the housing ladder. They must be catered for in some way.

Pensions must remain the fundamental pillar of long-term saving and this cannot be so generous as to compete with contributing to a pension.
 
A woman whose name I did not catch made a very good argument for having no annual cap but a lifetime limit - something I agree with.

She argued that many women take time out from earning to raise a family and would miss out if there was an annual cap. I have argued against an annual limit but had not considered this angle before which I will now add to my arsenal.
 
Eoin Fitzgerald of Financial Services Ireland issued a report yesterday I think with 5 recommendations

1) A tax incentive
2) No annual limit
3) A lifetime limit
4) Few investment restrictions
5) No minimum period.
 
I was deeply frustrated by the contribution made by the Competition and Consumer Protection Commission.

It was all about financial literacy and numeracy ( The Minister said he was 1000% behind that - I bit my tongue)

She said that a predecessor had launched the very successful "Do you know what a tracker is?" ad.

I had already spoken, but asked her at the coffee break

1) What did you do about tracker mortgages? Absolutely nothing. It was Charlie Weston, Padraic Kissane and I who dragged the Central Bank kicking and screaming to do something about them. With not a peep from the financially literate CCPC.
2) What did you do about mortgage rates when we were being charged the highest rate in the eurozone? Absolutely nothing. They left it to me and a few others to highlight the issue and they made no pronouncements on their own initiative.
3) What are you doing now about vulture funds? Absolutely nothing.

She told me that they have 240 staff. It's desperately depressing.
 
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