Revenue eBrief No. 019/26
28 January 2026
Amendment to Exempt Unit Trusts
Tax and Duty Manual Part 27-01-01 has been updated to reflect a Finance Act 2025 amendment. The update has been made to the introduction section to confirm that for the purposes of section 731(5) TCA 1997, a gain on the disposal of units in an exempt unit trust by an investment undertaking is not considered wholly exempt from capital gains tax. This means, in effect, a unit trust may not be considered an exempt unit trust where there are unit holders who are investment undertakings.