Administrative simplicity has been mooted as one of the most important features of an Irish SIA, including by the Minister for Finance, on foot of suggestions regarding the improvement of investment opportunities for Irish taxpayers such as in the Government’s Funds 2030 Report.

Accordingly, the panel were asked to discuss key characteristics of a well designed SIA, from a compliance and administrative perspective.

Investor-friendly tax treatment is one of the most important characteristics of a well-designed SIA writes McCann FitzGerald’s Deirdre Barnicle, who outlines the straightforward tax advantages that are part of Canada’s SIA regime, the TFSA, which is similar in its basic model approach to that of the UK’s ISA. In this model savings invested are treated as exempt income while in the product ‘wrapper’ making it eligible to tax-free gross roll up on income, dividends, and capital gains.

Supplementing this, a new report from Barclays offers a number of insights and recommendations for EU policymakers on the SIA from the lessons learned in the UK market since the introduction of the UK’s first SIA, the Personal Equity Plan, in 1987.

The latest iteration in the UK, the ISA, was introduced by UK Chancellor Gordon Brown (one of a number of financial innovations he was associated with during his term of office, such as the independence of the Bank of England) and it has been a huge success.

The value of investments in the UK’s ISA is ?730 billion (€910bn), with ?390bn of that in stocks and shares. Tax simplicity is suggested by Barclays in its Report conclusions on the shape of a successful SIA, and the ISA/TFSA approach wins out from this point of view, given its ease of administration while in the wrapper - ‘you can’t beat free’, being the principle.
By contrast, the Nordic models, notably the Swedish ISK suffer as being complex, based, in the Swedish case, for example on a complicated and unpredictable formula that levies tax inside the wrapper, based on a variable rate linked to the current market bond rate on Swedish bonds.

That said, Forvis Mazars’ Joe Walsh highlights the relative simplicity of the ISK’s tax model, based as it is on a low annual levy on the extant amount of the funds from year to year.
Walsh also sees the establishment of an Irish SIA as an opportunity to encourage the development of the core life skill of financial literacy from a young age (see page 7).

Recent changes in Luxembourg regarding the tax treatment of carried interest ‘expand the scope of eligible beneficiaries and funds’ writes BDO’s Angela Fleming. The expansion and increased attractiveness of Luxembourg’s regime highlights the many restrictions on Ireland’s tax treatment of carried interest which, as Fleming outlines, include restrictions around structure, duration, investment type and geography.

The changes in Luxembourg could offer a blue print for an improvement of Ireland’s regime with Forvis Mazars’ Walsh writing: ‘Industry voices argue that Ireland’s regime, while attractive on paper, is too restrictive in practice’ and that changes to the regime ‘could channel investment into areas of acute national need’ such as housing and other infrastructure.

The Department of Finance’s recent publications in relation to the R&D Tax Credit highlights the importance of the regime to Ireland’s FDI offering writes Eversheds Sutherland (Ireland) LLP’s Robert Dever. He writes that ‘the challenging circumstances in which many R&D companies are operating at present, including the ongoing threat of tariffs which can disrupt investment plans and trade patterns and create global tensions, means that the need to ensure that the tax system continues to support investment and employment in the Irish economy is as strong as ever.’

A key area of the R&D tax credit review will involve the outsourcing provisions of the regime. Forvis Mazars’ John Burke writes, ‘The requirement that R&D be largely performed in-house, combined with the restrictive cap for outsourced activities to universities or unconnected third parties, is viewed as misaligned with modern collaborative R&D models... The Department has signalled that these proposals will be examined.’

The latest developments around US tariffs in the wake of the US Supreme Court’s 20th February ruling are also examined. McCann FitzGerald’s Barnicle writes, ‘Although the Supreme Court’s rejection of Trump’s tariffs may at first glance seem like a positive development, the President’s reaction and subsequent threat of further tariffs has brought significant uncertainty to the future of transatlantic trade’. She points out though that ‘nearly 85% of Irish goods exports to the US are still exempt and that the effective rate for Ireland is one of the lowest across OECD countries.’

This article appeared in the March 2026 edition of the Irish Tax Monitor.