ETF deemed disposal in Ireland: the eight-year record

    Where the relevant fund regime applies, an eight-year anniversary can create tax even without a sale. Track each acquisition and the units still held. Use the event-date value, original cost and evidenced previous fund tax rather than resetting the history to today’s balance.

    FiscalFox editorial team · Product lead: Grant Sloane · Updated

    Calculate Irish investment tax

    Start with the correct anniversary basis

    For a fund running from its purchase date, each acquisition has its own anniversary. Monthly investing therefore creates a sequence of lots and dates. Selling part of the position changes the units left to test; a portfolio’s first purchase date is not a single anniversary for all later contributions.

    Revenue specifies a special 2022 starting point for certain ETFs covered by its former share-treatment guidance and subsequently found equivalent. That is not a general reset for Irish or other EU funds. Establish eligibility for that transition before selecting it in FiscalFox.

    Sources: Revenue: ETF classification and the 2022 transition (27-01A-03)

    Collect a dated valuation without selling the holding

    A deemed-disposal computation needs the units attributable to the lot and their value at the relevant event date. Keep the price, currency and conversion evidence with the purchase record. The anniversary is a tax calculation event; it does not mean you placed a sell order.

    When preparing the selected year in FiscalFox, resolve valuation evidence against the affected event. An upcoming anniversary is not a completed charge for a date that has not yet happened. Do not substitute an undated current price for an earlier anniversary value.

    Keep original cost and previous tax evidence

    For equivalent offshore funds, the original acquisition cost remains relevant after a deemed disposal. Tax already paid on earlier deemed events is taken into account on a later actual disposal under the applicable rules. Keep payment evidence linked to the original purchase lot.

    If only part of a lot is sold, the previous-tax record must follow the relevant units. A blanket portfolio credit can misstate the remaining history. FiscalFox’s separate fund schedule preserves the purchase references and any evidenced credit instead of blending it into ordinary share losses.

    Sources: Revenue: equivalent offshore funds and eight-year events (27-04-01)

    Reconcile a monthly investment history

    List each purchase date, ISIN, units and euro cost, followed by any partial sales or fund switches. Match those records to the remaining units. Add the relevant anniversary values and previous-tax evidence; keep later purchases out of an older lot’s anniversary.

    Use the source export alongside the fund event schedule to investigate a difference. An account total can look plausible while an individual lot has the wrong date or cost. Save the original files and backup so a later year can continue from the same evidence.

    Handle the return through the correct fund route

    A fund event does not belong in the ordinary share disposal total simply because no broker deducted tax. Equivalent offshore fund acquisitions, payments and disposals have their own Form 11 reporting requirements. The ordinary CGT December and January payment cycle is not a universal deadline for fund tax.

    The fiscal year, residence basis, regime and previous returns all matter to the fund record. FiscalFox’s current fund calculations concern supported 2025 and 2026 events. A later anniversary date is a tracking record, not a promise that today’s rate will apply in that future year.

    Sources: Revenue: equivalent offshore funds and eight-year events (27-04-01)

    Illustrative eighth anniversary in 2026

    A fictional standard equivalent offshore fund purchase on 15 October 2018 reaches its eighth anniversary on 15 October 2026. All units are still held, values are in euro and there is no earlier event tax.

    Illustrative eighth anniversary in 2026
    FigureAmount or date
    Purchase date15 October 2018
    Original cost€10,000.00
    Value at eighth anniversary€14,000.00
    Deemed gain€4,000.00
    2026 rate38%
    Deemed-disposal tax€1,520.00
    Cash received from a sale€0.00

    Questions and answers

    Do monthly ETF purchases share one eight-year date?

    For the normal purchase-date basis, each purchase has its own clock. Track the dates and remaining units of each lot.

    Does the 2022 transition apply to every ETF?

    No. Revenue describes a limited transition for specified ETFs previously covered by its share-treatment guidance. Irish and other EU funds do not receive a general 2022 reset.

    Do I pay the same tax twice when I eventually sell?

    The applicable fund rules take earlier deemed-disposal tax into account. Keep the original cost and evidence of tax paid so the later computation can reconcile the credit.

    Official sources

    Sources checked . Export instructions describe the file supported by FiscalFox.

    Revenue: ETF classification and the 2022 transition (27-01A-03)

    Revenue: equivalent offshore funds and eight-year events (27-04-01)

    Revenue: investment undertakings (27-01a-02)

    Revenue: fund tax reduced to 38% from 1 January 2026

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    Calculate Irish investment tax