BorderFolio/QQQ vs CNDX
QQQ vs CNDX for non-US investors
Last reviewed 3 September 2026
Two funds tracking exactly the same index — the Nasdaq-100 — in two different wrappers. If you have read any US-versus-UCITS comparison before, this one will surprise you: the Nasdaq-100 yields so little that the usual withholding argument for the Irish fund nearly vanishes, while the fee gap runs the other way and grows. What is left deciding the question is estate tax, a foreign-tax-credit nuance, and whether your broker will sell you the US fund at all. This page works through each, arithmetic first.
The two funds, side by side
| QQQ | CNDX / SXRV | |
|---|---|---|
| Full name | Invesco QQQ Trust | iShares NASDAQ 100 UCITS ETF USD (Acc) |
| Domicile | United States | Ireland (ISIN IE00B53SZB19) |
| Index | Nasdaq-100 | Nasdaq-100 — the same index |
| Structure | Unit investment trust | UCITS fund |
| Ongoing charge | 0.20% | 0.33% |
| Distribution | Distributing, quarterly | Accumulating — dividends reinvested inside the fund |
| Listing | Nasdaq, USD | CNDX in USD (London); EUR line SXRV (Xetra) |
| US-situs asset? | Yes | No |
Fund data as published by Invesco, iShares and fund data providers in September 2026. Expense ratios and listings change — the factsheet is the authority, not this page.
Unlike many US-versus-UCITS pairs, there is no index difference to argue about: both hold the roughly 100 largest non-financial companies listed on Nasdaq, with the heavy single-sector concentration that implies. The concentration is a feature of the index, not of either wrapper. One structural quirk is worth knowing: QQQ is a unit investment trust, an older structure that holds dividends as cash between quarterly distributions and does no securities lending — a small drag and a small simplification at the same time. Invesco also runs the other mainstream Irish wrapper, EQQQ (TER 0.30%, distributing, with an accumulating class); the full menu of UCITS routes to this index is on the companion page.
Where the dividend is taxed, and how many times
The mechanics are the standard ones for a US fund against an Irish fund; what is unusual here is how little money they apply to.
- QQQ is a US fund. Its distribution to you is US-source income, so your residence's rate from the IRS treaty table is applied to the entire distribution: 30% where there is no treaty or no documentation on file, 15% for many treaty countries, 10% for a few, 0% rarely.
- CNDX is an Irish fund. It suffers 15% US withholding on the dividends it receives, under the US–Ireland treaty. Ireland then withholds nothing from a non-resident holder, and because the share class accumulates, nothing is paid out to withhold from in the first place.
So far this reads like every other comparison of the two domiciles. The next section is where it stops doing that.
A worked example, with its assumptions in the open
$100,000 invested; gross dividend yield of the Nasdaq-100 assumed at 0.6%, so $600 a year. Nearly all of it is US-sourced, so no US/non-US split is needed. That low yield is the whole story here.
| Your residence | QQQ — withheld from you | CNDX — suffered inside the fund | Withholding difference per year |
|---|---|---|---|
| No US treaty (30%) | $180 | ≈ $90 | ≈ $90 in favour of CNDX |
| Treaty rate 15% | $90 | ≈ $90 | ≈ $0 — a dead heat |
| Treaty rate 0% | $0 | ≈ $90 | ≈ $90 in favour of QQQ |
Now the fee gap: 0.20% against 0.33% is thirteen basis points — $130 a year on the same $100,000, in QQQ's favour. Put the two columns together and the arithmetic is blunt: even with no treaty at all, QQQ's $130 fee saving exceeds CNDX's $90 withholding saving, so QQQ comes out roughly $40 a year ahead on pure annual drag. At a 15% treaty rate the withholding gap is zero and the full $130 stands. This is the opposite of the high-yield case — on a fund yielding 3%, the same 30% withholding would cost five times as much and swamp the fee gap. On the Nasdaq-100 it does not. Find your residence's rate — it is a published number, not an estimate.
One credit-side nuance pushes the same way. Withholding taken from you — the QQQ case — is often creditable against tax at home, where your residence taxes dividends and grants a foreign tax credit. The 15% suffered inside CNDX at the fund level generally is not: you never received the income it was withheld from, so there is usually nothing to claim a credit against. Whether that matters depends entirely on how your residence taxes you.
Estate tax: the asymmetry the yield cannot shrink
If the annual numbers now look like a clean win for QQQ, this is the section that keeps the question open. QQQ shares are US-situs assets. For a non-US, non-resident estate, US-situs assets above USD 60,000 can attract US estate tax at rates reaching 40% on the excess, unless an estate tax treaty raises that threshold — and the United States has estate treaties with only a limited number of countries. An Irish-domiciled UCITS such as CNDX is not a US-situs asset for this purpose.
A $40-a-year cost advantage is being weighed against a contingent exposure measured in percent of the whole position. Whether that exposure ever bites depends on how the assets are held and on the circumstances of an estate — which no tracker can compute — but it is the reason many non-US investors choose the Irish wrapper for this index despite the arithmetic above, and it is not an unreasonable trade.
Whether you can buy either one
Availability settles this question before any of the numbers do for a large group of readers. Retail investors in the EEA and the UK generally cannot buy QQQ, because US-domiciled ETFs do not publish the Key Information Document that PRIIPs requires; brokers block the order rather than the regulator blocking the fund. For them the choice is between Irish wrappers — CNDX, EQQQ and others — and the comparison worth reading is the one between those. Investors in most other jurisdictions can typically buy either through an international broker, subject to the broker's own rules.
Distributing against accumulating
QQQ pays out quarterly; the cash is visible, taxable in the ordinary way, and has to be reinvested by hand. CNDX reinvests internally: no cash lands, nothing to re-buy, nothing that could be mistaken for a deposit in a contribution tracker. But several residences tax accumulating funds anyway, on a deemed or imputed basis rather than on cash received, and a few tax them less favourably than distributing ones. At a 0.6% yield the sums involved are small either way — which is not the same as saying your tax office will ignore them.
What to do once you have chosen
Both wrapper effects on this page are invisible on a brokerage statement. The 15% suffered inside CNDX never appears anywhere — it is deducted before the fund is paid — and QQQ's investor-level withholding shows up as a line you notice once and forget. BorderFolio estimates both steps per instrument, using the domicile of each fund you actually hold against the tax residence you configure, and keeps the estimate attached to your real dividend history rather than to a hypothetical portfolio. If you hold both wrappers, or you moved and now hold the wrong one for your new residence, that is precisely the case it is built for.
Limitations
- The example is an illustration, not your portfolio. The 0.6% yield is an assumption; the Nasdaq-100's yield moves every year, and the balance between the fee gap and the withholding gap moves with it.
- Treaty rates depend on paperwork. Without valid documentation on file the statutory 30% applies whatever the treaty table says.
- The second step is not modelled here. Tax where you live, foreign tax credits and their caps, and the treatment of accumulating funds are all residence-specific.
- Estate exposure is contingent, not annual. Whether it ever applies depends on treaties, holding structures and the circumstances of an estate — none of which this page can assess.
- Not advice. This is an informational comparison of two fund structures, not a recommendation to buy or sell either. See the investment & tax disclaimer.