Ireland's ETF supremacy leaves little room for complacency

ireland etf supremacy

Ciarán Fitzpatrick, head of ETF Solutions at State Street in Europe, discusses why Ireland has a stronghold in the ETF space, the implications of digitization, as well as emerging ETF trends.

December 2023

Since the launch of the first European ETF around 20 years ago, Ireland has proven to be highly adept at spotting and capitalizing on emerging global investor interest in ETFs, and it has cemented a commanding lead in Europe that looks almost unassailable.

ETFs are a type of pooled investment, much like mutual funds, that are listed on stock exchanges such as Euronext, London Stock Exchange (LSE) and Xetra. Most of them passively track an index, like the Nasdaq or the CAC 40, but more recently there has been an increased appetite for more actively managed products.

SPDR S&P 500 (SPY), the first ETF to be introduced in the United States and listed on a national stock exchange, made its debut on January 22, 1993. It was developed by State Street to track the S&P 500 and it remains the world's most heavily traded ETF. This groundbreaking ETF revolutionized investor access to a wide array of asset classes and investment strategies.1

These funds then went on to attract an international investor following as well. Since 2000, when the first ETF launched in Europe,2 Ireland has been steadily building up its lead. Ireland domiciled ETFs broke the €1 trillion barrier for assets under management (AUM) for the first time at the end of June this year, putting it leagues ahead of second place Luxembourg with €295 billion AUM. This gave Ireland around 68 percent of the European ETF market, according to Morningstar.3

Comprehensive tax treaties
A key building block of this success is the double taxation treaty Ireland enjoys with the US, which reduces the withholding tax on US dividends to 15 percent from 30 percent. Ireland is the only European jurisdiction to hold such an arrangement for ETFs, and given global investor interest in US assets, this is a valuable concession. For example, the US comprises 42.5 percent of the global equities markets,4 according to the Securities Industry and Financial Markets Association, making it the world leader in this asset class.

In fact, Ireland has one of the most developed tax treaty networks in the world, making it a very attractive jurisdiction for many international investors. According to the Revenue Commissioners, Ireland’s tax authority, the country has comprehensive double taxation agreements with up to 76 countries.5 These jurisdictions include Australia, China, Hong Kong, India, Japan, Switzerland, Singapore and the United Kingdom, as well as with EU countries.

But there is more to Ireland's ETF success than tax treaties. It has a supportive regulator and a highly developed ETF ecosystem – covering areas such as administration, custody, legal, tax, accounting and auditing, product development and thought leadership.

Another factor behind Ireland’s success is the establishment of the International Central Securities Depository (ICSD), which provided centralized settlement for all Irish domiciled ETF issuers and, thereby, resulting in reduced fragmentation, boosted liquidity and narrowed spreads. These achievements have, to an extent, been counteracted by the additional costs of complying with the EU’s Central Securities Depositories Regulation (CSDR).

All these factors have made Ireland an ideal springboard for most asset managers looking to sell ETFs across Europe.

Emerging ETF trends
ETFs are evolving rapidly, and Ireland is well placed to benefit from these developments. Important trends include the emergence of the “ETF 3.0” model, more US asset managers seeking access to European investors, growth of ESG strategies and the move towards digitization.

ETF 3.0 can be characterized as “actively managed” ETFs. We are seeing a significant number of US asset managers converting their mutual funds into US structures, and in Europe, a growth in traditional active mutual fund managers seeking to enter the ETF arena with similar active strategies. ETF 1.0 are passive funds tracking an index, and version 2.0 are smart beta and thematic products replicating a particular investment strategy, be it income, growth, momentum or value.

This transformation is being driven by investors seeking lower fees associated with ETFs and the ability to receive more regular portfolio updates than typically seen with mutual funds. This could represent an important long-term trend, even if only a small proportion of mutual funds make the transition.

Data from Morningstar shows inflows into active ETFs grew by a net 14 percent during the first half of 20236 while passive ETFs managed a more modest 3 percent increase. Active products account for around 5 percent of the overall ETF universe.7

According to a Lipper Alpha Insight report, European asset managers held just over €14 trillion in assets at the end of June of this year.8 By contrast, ETF managers held €1.4 trillion in assets – suggesting a tantalizing growth opportunity for actively managed ETFs.

Well-established infrastructure
From a custody and administration point of view, turning mutual funds into ETFs in Ireland is relatively straightforward given both are regulated under the EU’s Undertakings for Collective Investment in Transferable Securities (UCITS), albeit not a practice the European market has seen frequently to date. The complexity in this switch is the change in the legal status of the investor from legal shareholder to beneficial owner.

There are some additional operational differences, such as “basket creation,” and as ETFs are exchange-listed, a capital markets team is needed to handle primary and secondary market engagements. Also, investor creations and redemptions in the primary market require detailed reporting to be generated by the service provider, though there are well-established solutions to make these processes run smoothly.

However, starting 28 May 2024, a challenge arises for European-based ETFs holding US-listed assets. While the US will shift to one-day settlement (T+1), Europe will remain on T+2, causing a synchronization gap. This means US transactions settle on T+1, but European participants will not receive funds or assets in the secondary market until two days later, potentially leading to increased costs.

Meanwhile, Ireland remains the destination of choice for the latest wave of US asset managers looking to sell products to European investors. Several asset managers, such as the tech-focused ARK Invest, are preparing to launch suites of ETFs into Europe that are to be domiciled in Ireland. As for ESG-themed funds, which are particularly popular with some European investors, Ireland continues to hold its own.

Digital risk
A potentially important emerging trend that Ireland should monitor closely involves digitization. Financial firms across the world are investigating how to use digitization to drive efficiencies and to democratize assets.

In Europe, for instance, Germany, Luxembourg and Liechtenstein lead in experimenting and creating regulatory frameworks to support innovation around tokenizing assets on blockchains.

While institutional investors dominate the European ETF landscape, there is some anticipation of increasing retail interest, supported by tokenization. PwC forecasts a 14 percent annual growth in European retail flows into ETFs until 2027,9 with Germany driving demand. Therefore, there is a risk of ETFs being established domestically rather than in Ireland should digitization become an important trend.

Nonetheless, Ireland’s position looks secure for now and, given its current momentum, its market share in Europe is likely to keep rising.

A version of this article was originally published in Irish Funds’ Autumn Newsletter 2023.


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