Welcome to KPMG Ireland’s Withholding Tax Study in relation to corporate Irish regulated investment funds, put together by our asset management practice.
Overview
In recent years withholding tax (WHT) management has attached increased focus from directors and investors, given the potential impact on NAV for some funds.
In our experience, there are instances where withholding tax relief mechanisms are not being fully utilised by funds, meaning that reclaim or relief opportunities are being overlooked – this is ultimately an opportunity foregone to increase NAV for investors.
This will only become more topical in the coming years as the “Faster and Safer Relief of Excess Withholding Taxes (FASTER)” Directive is implemented into local law across European member states. EU Member States have until the end of 2028 to transpose into domestic law (with the rules to become applicable as of January 1, 2030).
Scope and methodology of the study
This study analyses the WHT rates across different jurisdictions with respect to corporate Irish regulated investment funds in order to provide a snapshot of the expected rates applicable in each country, in addition to identifying any possible scope for relief.
We have included information in respect of more than 85 countries and analysed the WHT rates applicable to interest, dividends and capital gains applicable to Irish corporate funds (ICAV and plc), based on the rules in force as of January 1, 2025.
Other forms of regulated investment funds such as ILP’s and CCF’s have been omitted on the basis such funds are tax transparent and therefore WHT treatment depends on a look through approach for most investment jurisdictions.
For each country, we have identified the general WHT rates based on domestic law for each type of income, supplemented by the reduced WHT rate (i.e. the possibility of reduction) and the reclaimable WHT rate (i.e. the possibility of a tax reclaim).
We have also included guidance on the difficulty level of reducing and / or reclaiming WHT and indicate these levels using a traffic light system, based on our experience.
Next steps
Access the full study, including the detailed summary of withholding tax rates, below.
Get in touch
The KPMG network of EU tax professionals can help you assess how the key rules may impact your business.
Reach out to our team today to discuss how we can help you maximise withholding tax efficiencies further.
