Tax due on remittance of UK managed fund

[Smoneen]

I seem to be getting conflicting answers in relation to the tax treatment of a UK investment / bond on remittance to Ireland so hopefully someone here can help.

Irish resident, Irish domiciled with lump sum in managed fund in UK for 10+ years. Investment was made while the individual was resident in the UK.

On encashment & remittance to Ireland is it treated under CGT or income tax for tax purposes?

 

[Oisin19]

Irish res and domiciled so taxable on everything now irrespective of status when investment was made.

maybe dig out the prospectus or Investment Memorandum and try follow the following steps:

Is it an offshore fund?
If yes, did you have a material interest in it?
If yes, is it in a good or bad jurisdiction? UK is good
Would it be considered an equivalent to an Irish fund or not? If equivalent, then IT on income and gains and deemed disposal in year 8 (you may have missed this tax charge). If non equivalent, then IT on Income and CGT on gains with no deemed disposal and losses can be used.

If not an offshore fund normal CGT and IT should apply.

Clear as mud yeah?

I'd try and close off the offshore fund point first. After that, the information provided on encashment will be useful to decide the treatment of the receipt in your hands.

 

[Gordon Gekko]

What’s its name?

 

[Smoneen]

It’s actually a private equity fund arranged on an ELP basis. From what I can gather to date it’s not subject to IT or CGT in the UK due to the individual non-res status.
However what I can’t seem to get a definite steer on is if remitted to ROI how is it taxed?