Deloitte responds to the Funds Sector consultation

We recently made our submission to the Department of Finance in response to the Public Consultation - Funds Sector 2030: A Framework for Open, Resilient & Developing Markets.

This consultation sought feedback on topics including investment funds and asset management landscape, the regulatory and supervisory framework, assessing the impact of the funds sector, taxation of investment products, the role of the Irish Real estate investment trust (REIT), the Irish real estate fund (IREF) and the Section 110 regimes.

Among our comments we note the following:

• The current tax treatment of various types of investment products, particularly investments in funds such as ETFs, is unnecessarily complex.
• In our view, the tax treatment of funds should be reviewed and overhauled to simply the tax treatment and in turn increase compliance.
• If the treatment of fund investments cannot be simplified in the manner we suggest in our response and to remove uncertainty regarding the tax treatment of certain investments, a comprehensive list of various products and tax treatment should be developed by Revenue to assist taxpayers in completing their tax returns.
• We expect to see a global increase in demand for private assets. It is imperative that Ireland positions itself well to take advantage of this growth.
• ESG and the transition to net zero is a significant opportunity for the industry to support the wider governmental priorities in this area.
• In our view, the IREF regime should be maintained without any significant amendments. The tax exempt-status of the IREF together with the withholding tax mechanism on distribution of profits are a common feature of European and international funds.
• In our view there is a still a case for maintaining the REIT regime.