The Department of Finance recently published an implementation plan (the 'Implementation Plan' – available here) providing an update on the recommendations included in the Funds Sector 2030 report (the 'Report' – available here). The Report, which was published last year, seeks to ensure the resilience of Ireland's funds sector and included 42 recommendations across themes including ETFs, private assets, retail investment, and structured finance. Broadly, we believe that the Implementation Plan is a positive move in the right direction and have set out some key takeaways below:
- Potential for IREF reform and simplification in 2026: The Implementation Plan confirms that the Report recommendation for a public consultation on an entity-level tax for Irish real estate funds (IREFs) has now been abandoned in favour of a broader public consultation on simplifying the IREF regime. Following this consultation, which is due in early 2026, proposed amendments are expected to be implemented in next year's Finance Act. This a welcome development as the existing IREF rules are unnecessarily complicated and burdensome.
- Welcome progress for Irish individual investors: The Implementation Plan explains that a Government 'roadmap' will be published early 2026 setting out an approach 'to simplify and adapt the Irish tax framework to encourage retail investment' in Ireland. The Implementation Plan repeatedly references the EU Savings and Investment Union (or SIU), an initiative to encourage citizens to participate in investments outside of bank deposits. Tying the implementation of the Report's recommendations to the SIU clearly indicates the proposed direction of travel – improved and simplified tax rules for individual investors. This is in addition to the proposed reduction in the rate of tax on Irish domiciled funds and life products from 41% to 38% as part of Finance Bill 2025.
- ETF recommendations delivered: The Implementation Plan shows that the Central Bank has moved swiftly to address recommendations relating to ETFs – both of which are now delivered. In April 2025, the Central Bank published an updated UCITS Q&A to pave the way for establishing semi-transparent ETFs in Ireland. In addition, the Central Bank published a Q&A on UCITS ETF fund naming requirements. This underlines Ireland's commitment to ETFs as an industry sector.
- Prioritising private assets growth: The Report recommended supporting private assets in two ways – first, by reviewing AIF Rulebook requirements and second, by improving the attractiveness of the investment limited partnership (ILP). The Implementation Plan illustrates that these recommendations have been prioritised by both the Central Bank and the Department of Finance. The Central Bank published an updated AIFMD Q&A to clarify private asset-related provisions in the AIF Rulebook, and recently issued Consultation Paper 162 which offers welcome reforms for the private asset sector in advance of the transposition of AIFMD II (due April 2026). Finance Bill 2025 proposes helpful measures for ILPs, including a proposed dividend withholding tax exemption for certain shareholdings of not less than 51% in Irish companies. These actions should ensure the continued increase in the number of Irish-domiciled private asset funds.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
