787AH Exemption of AE provider schemes

This section provides that income arising to an AE provider scheme from investments (including dealings in financial futures and traded options) or deposits and from certain underwriting commissions are exempt from income tax. The exemption for underwriting commissions applies only to those chargeable to tax under Case IV of Schedule D, that is, casual transactions. Accordingly, it does not apply to the profits of an organised trade of underwriting which would be chargeable under Case I of Schedule D. It also provides that a unit in an AE provider scheme is not an asset of a pension fund for the purposes of Chapter 1A of Part 27 TCA. This ensures that where the AE provider scheme is structured as a Common Contractual Fund (‘CCF’), the CCF tax transparency rules do not apply.

Relevant Date: Finance Act 2025