The Roadmap for Deemed Disposal

Brendan Burgess

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Wider reform of retail investment taxation

The Roadmap also sets out the next phase of work on the wider taxation of retail investment.

Budget 2026 reduced the tax rate applying to Irish and equivalent offshore funds, and Irish and certain foreign life assurance products from 41 per cent to 38 per cent.

Building on that change, the Roadmap identifies three key areas for consideration in reforming the existing taxation regime from Budget 2028 and beyond:

  • reducing the rate of taxation;
  • reviewing the deemed disposal rule; and
  • introducing administrative simplifications.
These options will be subject to further analysis, including consideration of their Exchequer impact and the need to retain appropriate anti-avoidance protections.
 
Exactly right. It feels like groundhog day for meaningful reform. I think the executive summary is along the lines of:

"The Department of Finance intends to introduce an Investment Account in 2027. The tax treatment remains largely unspecified. The Government will continue thinking about deemed disposal, tax rates and administrative simplification. Loss relief is unlikely to change. No existing tax rules have changed. The roadmap acknowledges concerns with deemed disposal but does not provide any assessment of whether those criticisms are correct, any estimate of revenue effects from abolishing it, or any commitment to changing it."
 
It says that the Exit Tax should be CGT + 2%
Whilst it should be 20% and 22%
We may see 25% CGT and 27% Exit Tax
and
We all seem to be mistaken that Deemed Disposal is a Tax
 
I published this on the other thread but realised this is the better spot. This is astonishing can kicking, even for Ireland.

Timeline
14 Sep 2022: Report of the Commission on Taxation and Welfare - Foundations for the Future
Action: The Commission recommends that a working group should be established to review and propose changes to the taxation of funds, life assurance policies and other investment products with the goals of simplification and harmonisation where possible. The working group should be established with a net revenue-raising or neutral mandate.

6 Apr 2023: Funds Sector 2030: A Framework for Open, Resilient & Developing Markets
Action: Terms of reference published

Summer 2024: Govt receives Funds Review Report
Action: Delay publishing report until after 3 weeks Budget 2025

22 Oct 2024: Minister Chambers publishes Funds Review Report
Action: Report Recommendations to be reviewed and Implementation Plan published

7 Oct 2025: Funds Review Report Implementation Plan published
Action: After over a year for review, further time needed to present a Roadmap which will be published in early 2026, subsequently delayed to 31 August 2026

31 Aug 2026: Tánaiste Simon Harris and Minister of State Robert Troy publish Roadmap for the Taxation of Retail Investment
Action: No timelines for next steps. No changes made following Funds Review Report recommendations. Summarises issues for consideration only.
 
What is causing all the foot dragging on deemed disposal, its clear Simon Harris wants it gone, there have been multiple questions anout it in the dail and yet they are not able to move on it. Is there some secret hand behind the scenes holding it all up?
 
Irish Times have reported Government defers action on Deemed Disposal rules until Budget 2028, which is very disappointing.
 
It sounds like they do not know an exact figure for Deemed Disposal exit tax received per year, so are asking the providers to give this data, to better make a decision on when to/if reduce/remove it
 
Is there some secret hand behind the scenes holding it all u
Yes, probably. I have repeated in these fora that the tail wagging the dog is the Life products. Note that "anti avoidance" keeps getting a cameo outing. The accumulator ETFs are the problem. These need to be taxed on their internal dividend income. The most common (universal?) way to achieve this is to have the investor taxed on annual "deemed income". That is anathema to the Life companies.
 
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We're only coming up to the second Budget of a 5 year government. They always said reforms would take place over multiple Finance Bills.

https://www.oireachtas.ie/en/debates/question/2025-07-15/158/
 
Troy spoke out of turn last week and looks very foolish now for ‘taking (the wrong)words out of the ministers mouth’. Gombeens with no political courage. A charitable view might be they are doing nothing on DD to give the savings account a head start ? Is this plausible?
 
Didn't a junior ininister state that the DD issue had been sorted? I blame myself for believing this.
I stopped believing anything a politician says about DD years ago. I'd gotten it wrong so many times. I now have a "I'll believe it when I see it" approach. Sad to see that they are going to continue kicking the DD football down the road, while they figure out how to generate tax income from existing investments. You'd think someone would have come up with a solution by now...
 
The Department appears to be asking why Irish people do not invest more while simultaneously preserving many of the tax features that investors identify as barriers to investing. If policymakers are unwilling to accept some short-term revenue risk in order to encourage long-term capital accumulation, retail participation may remain low, which in turn makes further reform harder to justify politically.
  1. Policymakers worry about immediate Exchequer costs and avoidance risks.
  2. Therefore they are reluctant to give substantial tax advantages to retail investors.
  3. The resulting tax regime makes long-term equity investing less attractive than it might otherwise be.
  4. Household savings remain concentrated in deposits, pensions and property.
  5. Because retail participation remains low, policymakers continue to view investment incentives as niche measures benefiting a relatively small group.
  6. Reform therefore remains politically difficult.
This strikes me as a coherent "Catch-22" story.

Ireland had an opportunity to make low-cost diversified investing substantially more attractive by addressing deemed disposal and the differential tax treatment of ETFs. Instead, the roadmap largely preserves the existing framework and proposes further review. The result may be an Investment Account that changes the wrapper through which investments are held without materially changing the underlying incentives.

Ireland has historically channelled large amounts of household wealth into property. The State says it wants more participation in capital markets. But the roadmap does not currently offer sufficient clarity for a saver choosing a globally diversified ETF over existing alternatives. Instead, it reflects a mentality that prioritises securing tax receipts today over maximising the future stock of taxable wealth. The question is whether collecting somewhat less tax from successful long-term investment compounding might ultimately produce a larger tax base twenty or thirty years from now.

Before this "roadmap", investors wanted answers to questions like is DD8 going? is the 38% rate changing? Will ETFs move closer to CGT? will loss treatment improve? What exactly are the terms of the new account? After publication, we got few answers. If the Government had announced "DD8 will remain, but investors can use a low-cost account with a transparent 1% annual levy instead", people could at least evaluate the proposal.

Instead, we have a roadmap that hints at a new account while leaving most of the economically important details unspecified.

The biggest unanswered question remains exactly the same as before this roadmap - will Ireland ever address DD8 and the broader taxation of ordinary ETF investing, or will reform be confined to a new provider-managed limited wrapper? The danger is that once the Government becomes invested in the success of the new Investment Account, policy attention shifts from reforming the underlying tax regime to promoting the wrapper itself.
 
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Only Irish Times are reporting on this no action on Deemed Disposal til 2028 or later.

Can't find anything from RTE, Indo, the Journal, etc on it
The report is here https://assets.gov.ie/static/documents/a5d640c2/Roadmap_for_the_Taxation_of_Retail_Investment.pdf

section 5.2 has this:

This Roadmap identifies, at a high level, three key levers that will be considered as part of the
reform of the existing regime for the taxation of retail investments in the context of Budget 2028
and beyond and following the introduction of the investment account in Budget 2027.
These key levers have been identified as having the potential to simplify the current taxation
regime, while maintaining the underlying gross roll-up regime for investment funds and life
assurance products, which is an important aspect of Ireland’s success in the financial services
sector.
The levers are as follows:
 Reduce the rate of taxation
 Review the deemed disposal rule
 Introduce administrative simplification
 
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