French asset manager Amundi has continued its migration of exchange-traded funds from Luxembourg to Ireland, seeking to capitalise on a significant tax advantage related to US dividend withholding tax. The firm completed the transfer of its Luxembourg-domiciled $6.966bn MSCI World V, which was absorbed on 21 February 2025 by the Amundi MSCI World UCITS ETF, a sub-fund of the Amundi ETF Irish collective asset management vehicle (Icav).
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As part of the restructuring, the $7bn ETF--Amundi’s third-largest fund domiciled in Luxembourg--was merged with a larger $11.103bn Irish counterpart already housed within Amundi’s Icav framework. Following the merger, the combined assets under management totalled approximately $18.1bn.
The move underscored Amundi’s broader strategy to optimise tax efficiency, particularly through Ireland’s double taxation treaty with the US. This means that withholding tax on dividends is 30% in Luxembourg versus 15% in Ireland.
A representative of Amundi told Paperjam, that “Ireland offers significant advantages for ETFs investing in US equities, primarily due to reduced withholding tax on dividends. This means that investors benefit from higher net returns in the long term. This decision was taken after a thorough review, always with the interests of our clients as the guiding principle.”
The spokesperson added, “This move of fund domicile, which is technically a fund merger, means that the investors will receive an improved performance in the long term with an unchanged exposure. As this fund merger is considered as a sale of shares followed by an acquisition of new shares, it may trigger taxation on gains. In Luxembourg, if the investor has held his investment for a period shorter than six continuous months. If he has held the investment for a period longer than six continuous months, there should be no tax impact.”
“There are no other merger of this kind planned,” remarked the representative.