On 10 September 2025, IRE FUNDS issued reforms proposed for Budget 2026.
- IRE FUNDS, as part of ongoing engagement with government stakeholders, formalized the industry’s key priorities in a Pre-Budget 2026 submission, Unlocking Private Assets to Drive Ireland’s Long-Term Competitiveness and Growth.
- Builds on extensive discussions over recent months, reflects continued commitment to ensuring Ireland remains a globally competitive centre for funds/asset management.
- The targeted reforms proposed for Budget 2026, including a DWT exemption for Investment Limited Partnerships, are measured, low-risk adjustments that bring Ireland into line with peer jurisdictions.
Five Key Asks
- Exempt Investment Limited Partnerships (ILPs) from Dividend Withholding Tax (DWT).
- Under current rules, ILPs are excluded and dividends paid to them are subject to withholding tax, even though often the tax is refunded late; this reduces returns, complicates structure, making Ireland less competitive.
- Broaden Anti-Reverse Hybrid Rules for Tax Transparency: expand their scope so private asset funds can hold more than 10% in a single issuer while still being tax-transparent; current limitation is constraining for infrastructure, real-asset funds.
- Expand the Dividend Participation Exemption: allow dividends from companies outside EU/treaty countries (excluding only zero-tax or non-cooperative jurisdictions), so Ireland can be more attractive as a holding location for global structures.
- Extend the Substantial Shareholding Exemption: include gains from disposing of non-trading subsidiaries and shares regardless of geography or activity; currently, gains are taxable unless the company is in an EU/treaty country and is trading.
- Modernize Section 110 Regime: adjust special purpose vehicle (SPV) rules to retain Ireland’s attractiveness for securitization, infrastructure/project finance, etc.
- Section 110 Regime suggested updates correct unintended impacts of recent rule changes on credit, adjust the Day 1 €10mn EUR asset threshold, extend election periods, consolidate overlapping interest-deductibility rules.
