Ken O'Flynn (Cork North-Central, Independent Ireland Party)
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82. To ask the Minister for Finance the total revenue collected by the State specifically from deemed disposal taxation on EU-domiciled Exchange Traded Funds and other collective investment undertakings subject to the eight-year deemed disposal rule in each of the years 2015 to 2025 inclusive; the estimated revenue projected for each remaining year of the current tax regime; and if he will make a statement on the matter. [17594/26]

Ken O'Flynn (Cork North-Central, Independent Ireland Party)
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83. To ask the Minister for Finance the total number of individual taxpayers who filed a deemed disposal liability on Exchange Traded Funds or other collective investment undertakings in each of the years 2015 to 2025 inclusive; the average deemed disposal tax liability per individual in each year; the total number of individuals who were required to sell holdings in order to meet a deemed disposal tax liability in each year; and if he will make a statement on the matter. [17595/26]

Ken O'Flynn (Cork North-Central, Independent Ireland Party)
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84. To ask the Minister for Finance the total administrative cost to Revenue of collecting deemed disposal taxation on Exchange Traded Funds and collective investment undertakings, including staff costs, systems costs, compliance overhead, and enforcement activity, in the most recent year for which data are available; how this administrative cost compares to the total revenue collected from deemed disposal on these instruments in the same year; and if he will make a statement on the matter. [17596/26]

Ken O'Flynn (Cork North-Central, Independent Ireland Party)
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85. To ask the Minister for Finance whether his Department or Revenue has conducted any assessment of the ratio of administrative cost to revenue collected specifically in respect of the deemed disposal regime as it applies to Exchange Traded Funds; if not, the reason therefor; whether he considers the current regime to represent value for money from a tax collection efficiency standpoint; and if he will make a statement on the matter. [17597/26]

Ken O'Flynn (Cork North-Central, Independent Ireland Party)
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91. To ask the Minister for Finance the number of individual taxpayers who crystallised a deemed disposal loss on Exchange Traded Funds or collective investment undertakings in each of the past five years; the total value of those losses; whether those taxpayers were entitled to any relief on those losses against other income or gains; and if he will make a statement on the matter. [17603/26]

Ken O'Flynn (Cork North-Central, Independent Ireland Party)
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99. To ask the Minister for Finance the number of individual investors who will face their first deemed disposal event on Exchange Traded Fund holdings in each of the years 2026, 2027, and 2028; the estimated aggregate tax liability that will crystallise in each of those years; whether Revenue has assessed the capacity of individual investors to meet these liabilities without being required to sell holdings; and if he will make a statement on the matter. [17655/26]

Ken O'Flynn (Cork North-Central, Independent Ireland Party)
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101. To ask the Minister for Finance the estimated annual cost to the Exchequer of abolishing the deemed disposal regime on Exchange Traded Funds entirely and replacing it with a standard capital gains tax charge on actual disposal at the standard 33% rate; how this cost compares to the current annual revenue generated by the deemed disposal regime on these instruments; and if he will make a statement on the matter. [17657/26]

Ken O'Flynn (Cork North-Central, Independent Ireland Party)
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102. To ask the Minister for Finance whether he has considered, as an alternative to full abolition of the deemed disposal regime, extending the deemed disposal interval from eight years to fifteen or twenty years; the estimated revenue impact of such a change; whether such an extension would materially reduce the distortive effect of the regime on long-term investment behaviour; and if he will make a statement on the matter. [17658/26]

Simon Harris (Wicklow, Fine Gael)
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I propose to take Questions Nos. 82, 83, 84, 85, 91, 99, 101 and 102 together.

The deputy has asked a number of questions about the cost of deemed disposal. The tax revenue arising from the taxation of investment funds and life assurance policies, including deemed disposal rules, was examined in the context of Budget 2026. The information available to Revenue does not allow them to isolate the tax returned due to deemed disposal rules from other chargeable events which give rise to a tax liability. Chargeable events include:

• the making of relevant payments,
• the redemption of the investment,
• the transfer by an investor of their investment, and
• the ending of an eight-year period following the acquisition of the investment and then every eight years thereafter. This is commonly referred to as a deemed disposal.

Therefore, while it is possible to identify the amounts of tax paid by funds in respect of unit holders, being Investment Undertaking Tax (IUT), and income tax accounted for by individuals in respect of their investments in Irish domiciled funds and offshore funds, it is not possible to provide a breakdown of the tax which relates to the eight-year deemed disposal nor is it possible to provide data on the number of individuals who are impacted by the deemed disposal rule.

On the basis of the information available to Revenue, and based on tax paid over the last eight years, if it was assumed that all tax paid by funds in respect of unit holders, tax paid by life companies in respect of policy holders, and income tax accounted for by individuals in respect of their investments in Irish domiciled funds, offshore funds and life products were as a result of deemed disposal, removing deemed disposal could give rise to a potential cost of €284 million. For Budget 2026, an estimate was prepared for the Exchequer impact in a year where deemed disposal did not apply, assuming that deemed disposal was closer to 50% of the total tax paid. This assumption results in an estimated full year cost to the Exchequer of €142 million for the removal of deemed disposal for investment funds and life assurance products.

However, it is important to note that the actual cost could vary where the proportion of tax which arises from deemed disposal rules is higher or lower, as well as where the gains in a particular year are larger or smaller than the eight-year average used for this estimate.

The table below provides the estimated amount of overall tax arising from 2016 to 2024 in respect of investments in investment funds, including IUT and income tax on Irish domiciled funds and certain offshore investment funds, which includes amounts in respect of ETFs. Data for 2025 is not yet available. Revenue cannot provide the 2015 figures in the time available to provide a response.

** IUT and LAET represent the amount of tax paid to Revenue. It is not possible to identify whether the figures for IUT and LAET represent amounts taxed at 25% in respect of corporate investors or 41% in respect of individual investors.

As regards the administration costs to Revenue of collecting and administering the tax from deemed disposals, Revenue operates an integrated tax and customs administration and therefore in most instances the costs of administering a single tax cannot be quantified.

It should be noted that Budget 2026 included a commitment to the publication of an approach to the taxation of retail investment, which will set out an approach to simplify and adapt the tax framework to further support retail investment. The work underway includes consideration of the Funds Sector 2030 Report deemed disposal, as well the European Commission’s recommendation on Savings and Investment Accounts.