I note the Deputy's query regarding the eight-year deemed disposal and it's impact on investors.
Finance Act 2006 introduced the eight-year deemed disposal for all investments that benefit from gross roll-up: that is, investments in Irish funds, investments in life policies and investments in offshore funds that were similar to Irish funds.
The eight-year deemed disposal was introduced as a new category of ‘chargeable event’ for the purposes of exit tax. This amendment was designed specifically to prevent the avoidance of tax by way of indefinite deferral of tax.
The Deputy may be aware that last year, on 6 April 2023, my Department published the Terms of Reference for a review of Ireland’s funds sector - ‘Funds Sector 2030: A Framework for Open, Resilient & Developing Markets’. The review is wide ranging and looking at a range of issues relevant to the funds sector, taking into account the recommendations in this area of the Commission on Taxation and Welfare 2022 report, Foundations for the Future.
A draft report was submitted to me for consideration in recent weeks and this is in line with the Review’s Terms of the Reference. The review was wide ranging and examined a range of issues relevant to the funds sector.
As part of my consideration of the draft report, I will consider the appropriate timing for the publication of the Funds Review and will make it available on the website of my Department.
As with all areas of tax policy, the taxation of savings and investments will be kept under review throughout the annual budgetary and Finance Bill process.