Written answers

Tuesday, 23 September 2025

Photo of Emer CurrieEmer Currie (Dublin West, Fine Gael)
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206. To ask the Minister for Finance the amount of tax revenue raised from the operation of the deemed disposal rules under the capital gains tax code, broken down per year, from 2020 to present; and if he will make a statement on the matter. [49583/25]

Photo of Paschal DonohoePaschal Donohoe (Dublin Central, Fine Gael)
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The Deputy is seeking details on the amount of revenue raised from the operation of the deemed disposal rules under the Capital Gains Tax system. I understand this to be a reference to the eight-year deemed disposal rule that applies to investment undertakings.

Section 58 of the Finance Act, 2000 introduced the gross roll-up taxation regime for certain categories of investment undertakings. Under the regime, there is no annual tax on income or gains arising to a fund. However, a fund has responsibility to deduct exit tax in respect of payments made to certain unit holders in that fund. In general, exit tax must be deducted on the occurrence of a chargeable event which includes, for example:

  • on the making of a payment by a fund to a unit holder.
  • on the redemption of the investment.
  • on the transfer by a unit holder of his or her entitlement in the investment.
  • on the ending of an 8-year period beginning with the acquisition of a unit in a fund, and each subsequent 8-year period beginning when the previous one ends. This is commonly referred to as a deemed disposal.
The deemed disposal rules were designed specifically to prevent the avoidance of tax by way of the indefinite deferral of exit tax which is in the form of an Investment Undertakings Tax (IUT). I am advised that a breakdown of the IUT raised from the operation of the deemed disposal roles is unavailable, as investment funds are not obliged to report the category of chargeable event the IUT relates to at the time of making the payment. The gross IUT receipts collected in 2024 was €73,458,926.

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