I propose to take Questions Nos. 369 and 448 together.
Real Estate Investment Trusts (REITs) are corporate entities, and as such pay dividends to their shareholders. Dividend Withholding Tax (DWT), which is charged at 25%, must be applied to REIT distributions, other than those distributed to certain limited classes of investors such as pension funds and charities as they are more generally exempt from tax.
Irish Real Estate Funds (IREFs) are fund vehicles and therefore are not subject to DWT. They are instead subject to a 20% withholding tax on distributions to non-resident investors. Furthermore, Irish resident individuals/corporates are subject to investment undertakings tax. Certain categories of investors such as pension funds, life assurance companies and other collective investment undertakings are generally exempt from having IREF withholding tax applied provided the appropriate declarations are in place.
The yield from changes in the rates of withholding taxes on REITs and IREFs would be dependent on the level of future distributions by these entities. As such there is no basis available to provide an accurate estimate of these future distributions.
However, the Deputies may be interested to note the information published on IREFs in Table 18 of the Revenue research report which is available at www.revenue.ie/en/corporate/documents/research/ct-analysis-2021.pdf, which includes information for 2017-2019, based on returns filed.