CPDStore Ireland

Offshore fund holdings are increasingly common in client investment portfolios — yet the Irish tax treatment remains one of the most misunderstood areas of tax practice. By equipping yourself with clarity on this topic, delegates can spot compliance risks early, structure pre-move planning effectively, and build deeper advisory relationships with clients holding foreign investments.

This course cuts through the complexity of the tax legislation. Delegates will learn how to classify offshore funds, understand why a UK ISA is fully taxable in Ireland and navigate the punitive 8-year deemed disposal rule. For accountants advising returning emigrants, internationally mobile professionals, or DIY investors who've inadvertently purchased non-Irish ETFs, this session equips them with the tools to protect their clients and add genuine value to their practice.

Mairead Hennessy covers the following topics during this course:

• Core Definitions & Classification Framework
   What makes an investment an "offshore fund"? What is a "material interest"? The foundational definitions under Section 743 TCA 1997, the decision tree for spotting offshore funds in client portfolios, and why classification drives everything — tax rate, timing of charges, and reporting obligations.

• The Funds Tax Categories & Rate Summary
   Learn which funds qualify for each bracket, what "good" and "bad" jurisdictions mean in law, and the critical distinction between equivalent and non-equivalent funds.

• The 8-Year Deemed Disposal Rule & Cash-Flow Planning
   The single most distinctive (and disruptive) feature of the offshore funds regime. How it works, why it catches investors off guard, the cost base reset, and practical strategies for managing large deemed disposal liabilities without forcing a real sale. Real-world scenario: a client returning to Ireland after 8 years abroad facing a surprise €57,000 tax bill.

• UK ISAs, Non-Domiciled Investors & Death
   ISAs are not tax-free in Ireland. Unpack the remittance basis for non-domiciled residents (what it covers and what it doesn't), the punitive deemed disposal on death, and the s.104 CAT credit planning point that determines who should inherit an offshore fund.

• Compliance, Reporting & Common Pitfalls
   Form 11 requirements, record-keeping obligations, and the five most common mistakes practitioners make — from assuming foreign exemptions carry over to Ireland, to forgetting that losses are ring-fenced within equivalent fund holdings, to overlooking the tax charge on death. Includes a practical checklist for client onboarding.