We see this common scenario with our customers. You buy an ETF. You don’t touch it. Then someone on Reddit mentions that Revenue will tax your gains after 8 years even though you haven’t sold anything, and you’re fairly sure they’re winding you up.
They’re not. It’s called deemed disposal, it’s real, it barely exists anywhere else in the world, and it catches thousands of Irish investors off guard every year. Here’s what it is, what it actually costs, what to do if you’ve already missed one, and how to handle it without losing a weekend to Revenue’s website.
What deemed disposal actually is
On the 8th anniversary of buying units in an ETF (or any fund in the exit-tax regime), Revenue treats you as if you sold those units at their market value that day (a “deemed” disposal) and taxes the paper gain.
You haven’t sold. No money has landed in your account. The tax is due anyway.
Why does the rule exist? Because funds grow tax-free on the inside, the dividends are reinvested with no tax along the way. Deemed disposal is Revenue’s way of collecting something at least every 8 years rather than waiting decades.
The rules of the regime, in one place
- Rate: 38% on gains versus 33% CGT on ordinary shares. Down from 41% in Budget 2026.
- No annual exemption: the €1,270 CGT allowance does not apply to ETFs.
- No loss relief: any investment taxed under the offshore funds regime does not allow losses on one product to offset gains on another product.
- Every purchase has its own 8-year clock. Since 2018 monthly buys means a rolling series of anniversaries from 2026 on, each one its own deemed disposal. On partial sales, first-in-first-out decides which units went.
- Credit when you actually sell: tax paid on a deemed disposal is credited against the tax due when you genuinely sell those units i.e. you’re prepaying, not paying twice.
- If the fund value has fallen since the deemed disposal: the earlier overpayment can be recovered/offset when the real sale happens.
An example:
In March 2018, Mark invests €10,000 in a world-index ETF. He never sells. By March 2026, the 8-year anniversary, it’s worth €19,000.
- Deemed gain: €9,000
- Tax at 38%: €3,420
- Payable through his Form 11 for 2026, due 18 November 2027 if filing online.
Mark still owns every unit. When he eventually does sell, the €3,420 he’s already paid is credited against the final bill.
“I’ve already passed my 8-year mark and never filed. Am I in trouble?”
This is the question behind most of the panicked searches! A missed deemed disposal is one of the more common things we see, and Revenue treats people who come forward very differently from people it tracks down. What actually happens: (1) you still owe the tax, plus statutory interest for the late period; (2) coming forward unprompted, by amending your return or making what Revenue calls a qualifying disclosure, generally protects you from the heavier penalties; (3) the work itself is finding the fund’s value on the anniversary date, calculating the gain, filing and paying.
The one bad move is waiting as interest keeps ticking and your options narrow. This is a situation we handle for customers regularly for a separate consultation fee.
Which of your investments does this apply to?
Rule of thumb: if it’s a UCITS ETF or fund domiciled in Ireland or the EU, which covers nearly everything on Degiro, Lightyear, Trade Republic, Trading 212 and eToro’s ETF range, it’s in the exit-tax regime. Individual shares (Apple, Ryanair, Bank of Ireland) are not; they stay under ordinary CGT.
Is deemed disposal going away?
Not yet. The Government’s Funds Sector 2030 review recommended removing it, and Budget 2026 cut the rate from 41% to 38%, a signal of direction, not the destination. As of today, deemed disposal is still the law and anniversaries still trigger tax. Whatever changes, we’ll update this page and update our newsletter subscribers.
The record-keeping reality (and how to make it painless)
For every purchase you’ll eventually need: date, amount invested, units bought and the value at each 8-year anniversary. Your platform’s annual statement has most of this.
Declaring your deemed disposal
Deemed disposal goes on your Form 11. Whether you have one tidy lump-sum investment or you’ve been investing monthly across a few ETFs for years, FastTax.ie can handle it. Tell our guided tool what you bought and when and we do the calculations. From €145 that’s the Form 11 covered for another year.
For more guidance about tax on online investing, see our guide: Online Investing Tax in Ireland: How Savings, ETFs, Shares and Dividends Are Taxed.
