Revenue Note for Guidance

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Revenue Note for Guidance

739I Common contractual funds


This section makes provision for the tax treatment of an investment vehicle called a Common Contractual Fund (CCF). A CCF is a form of investment fund structure based on a contractual relationship between the participating investors. The purpose of a CCF is to allow for the pooling of assets in order to achieve lower costs and investment efficiencies. A limited type of CCF, formed under the EU UCITS Regulations, has been available in Ireland since 2003. The Investment Funds, Companies and Miscellaneous Provisions Act 2005 subsequently allowed for the setting up of a general form of CCF, not confined by the UCITS regulations, in the State.

The section sets out the taxation regime in respect of all types of CCF. The core provision of the taxation regime is that all CCFs will be tax transparent, as long as the unit holders are institutional investors (in other words, not individuals) and that certain reporting requirements are met. CCFs may also avail of existing withholding tax exemptions available to other collective investment undertakings.



(1) A common contractual fund (CCF) covers both the general CCF vehicle provided for under the Investment Funds, Companies and Miscellaneous Provisions Act 2005 and the CCF vehicle formed under the EU UCITS Regulations that has been available in Ireland since 2003.

(1)(b) The definitions in section 739B of relevant income, etc. (as listed in this section) all relate to “investment undertakings” (as defined). Their meanings are modified in relation to CCFs because the proposed CCFs are outside the scope of section 739B (as they are a new form of investment undertaking that is not defined in section 739B).

(2) A CCF is not chargeable to tax and the entities are tax transparent. This means that the profits (income and gains) arising or accruing to it are treated as arising or accruing to the unit holders in proportion to the value of the units beneficially owned by them, as if such profits did not pass through the hands of the CCF.

(3) The provisions apply only where each unit in the CCF is held by institutional investors such as pension funds, life assurance companies, etc.

(4) Information reporting arrangements provide that the CCF must make annual electronic returns to the Revenue Commissioners in respect of profits made and benefits accruing to each unit holder.

(5) CCFs are exempt from deposit interest retention tax (DIRT), as is the case with other investment undertakings.

Relevant Date: Finance Act 2021