Why one product can be taxed four different ways
Ireland did not design a single system for investment funds. Irish funds and life assurance products sit in the gross roll-up regime, where nothing is charged while you hold and a chargeable event settles at exit tax, which Budget 2027 cut. Offshore funds were brought in separately and split by where they are established and what they legally are, which produces four more outcomes between them: exit tax, Capital Gains Tax, a special offshore rate, and marginal income tax with USC and PRSI. Which one a fund lands in turns on its domicile, whether it is equivalent to an Irish fund and, outside the treaty network, whether Revenue has certified it as distributing. The Department of Finance's own retail investment roadmap calls the result overly complex.
Life assurance splits the same way and less visibly. Where the insurer that wrote a policy is established decides who operates the tax, what you have to file and when the eight-year clock starts, and a policy from outside the EU, EEA and OECD treaty network is in a different position again. Cutting across all of it is one anti-avoidance rule worth knowing about before you meet it: where the investor can influence which assets the fund or policy holds, the personal portfolio rules replace ordinary exit tax, with a further rate for a gain that is not correctly returned. Finance Act 2025 cut exit tax and deliberately left those rates alone, and Budget 2027 announced no change to them either.
That was survivable while a shortcut existed: Revenue used to confirm that ETFs domiciled in the USA, the EEA or an OECD treaty state followed the treatment that applies to shares generally. It has since withdrawn that confirmation. A treatment somebody was told about years ago may no longer be the right one, and that can change when the eight-year rule reaches the holding. The deemed disposal calculator works out the year it does.