Irish-domiciled alternatives to SPY — S&P 500 UCITS ETFs compared

The candidates, side by side

Fund data as published by the issuers and fund data providers in September 2026. Fees, share classes and listings change — the factsheet is the authority, not this page.

All four track the same index, so the holdings argument that complicates other wrapper comparisons does not arise here. Everything on this page is about the wrapper: what it charges, where its dividends are taxed, and whose rules apply to the shares. One availability point settles the question for many readers before anything else does: retail investors in the EEA and the UK generally cannot buy SPY at all, because US ETFs do not publish the KID that PRIIPs requires. For everyone else, the comparison below is live.

SPY's structure is part of the story

SPY launched in 1993 and is structured as a unit investment trust — a legal form its younger rivals abandoned. A UIT cannot immediately reinvest the dividends it receives, so cash sits idle between quarterly distributions, and it cannot lend securities to offset costs. Both are small structural drags that funds organised the modern way do not have. None of this makes SPY a bad fund — its scale and liquidity are unmatched — but it means the oldest ETF in the world is not automatically the most efficient way to hold its own index, even before domicile enters the picture.

The fee comparison flipped

UCITS funds have historically charged more than their US counterparts, and most comparisons on this site say so. This one is the exception. In late 2024 State Street cut the TER of its Irish S&P 500 fund to 0.03%, undercutting SPY's 0.0945% — the same issuer, the same index, and the European wrapper is now the cheaper of the two by roughly $65 a year on $100,000. Against SPYL, SPY loses on fees at every treaty rate, which removes the usual trade-off where a non-US investor pays more in fees to save on withholding. Note honestly that the VOO comparison reads differently: VOO charges 0.03% itself, so against Vanguard's US fund the fee argument disappears and only the tax mechanics remain.

Where the dividend is taxed, and how many times

Every fund on this page receives the same US dividends from the same 500-odd companies. The difference is what happens between the companies and you.

• SPY is a US fund. Its distribution to you is US-source income, and your residence's rate from the IRS treaty table is applied to the whole distribution: 30% where there is no treaty or no documentation on file, 15% for many treaty countries, 10% for a few, 0% in rare cases.
• The Irish funds suffer 15% US withholding inside the fund on the US dividends they receive, under the US–Ireland treaty. Ireland then withholds nothing from non-resident holders — and an accumulating class pays nothing out to withhold from in the first place.

So the comparison is: a fixed 15% suffered inside the fund, against your own treaty rate applied on the way to you.

A third structure exists and deserves a paragraph. Swap-based (synthetic) S&P 500 UCITS ETFs do not hold the shares directly; they receive the gross total return of a qualified index through a swap, with no US withholding inside the fund at all. That is a genuine mechanical difference, bought at the price of counterparty exposure and a different cost structure. This page does not compare their fees — if the synthetic route interests you, check the replication method and the factsheet of the specific fund, not a summary.

A worked example, with its assumptions in the open

$100,000 invested; gross dividend yield of the index assumed at 1.3%, so $1,300 a year. The Irish funds suffer 15% of that inside the fund — about $195 — whatever your residence. SPY's column is your treaty rate on the whole distribution.

And unlike most US-versus-UCITS comparisons, the fee line now points the same way as the withholding line: SPYL is about $65 a year cheaper on the same $100,000. Against SPYL, SPY loses on fees at every treaty rate and on withholding at every rate above 15%. Only a low- or zero-treaty-rate residence has an arithmetic case for SPY, and even there the fee gap eats into it. Find your residence's rate — it is a published number, not an estimate.

One nuance the table cannot show. Investor-level withholding — the SPY kind — is often creditable against tax at home, so a residence that taxes dividends and grants a foreign tax credit can recover much of it. Fund-level withholding — the 15% suffered inside a UCITS — is generally not creditable to you, because it was never withheld from you. Whether that flips anything depends on how your residence taxes dividends, which this page does not model.

Estate tax: the asymmetry that is not about percentages

SPY shares are US-situs assets. For a non-US, non-resident estate, US-situs holdings 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. The Irish-domiciled funds are not US-situs assets for this purpose, whichever share class you hold.

A long-term index investor crosses $60,000 in an ordinary month, with no notification from the broker and no change of state anywhere on a dashboard. Whether it ever bites depends on how the assets are held and on the circumstances of an estate — but knowing which side of the line you are on is the point.

Where SPY still wins: trading

SPY's liquidity is unrivalled — the deepest options market of any ETF and spreads measured in fractions of a cent — and for anyone trading intraday or writing options against the index, no UCITS fund is a substitute. That advantage is largely irrelevant to a long-term holder making monthly contributions: UCITS spreads are wider, but on a buy-and-hold timescale the difference is a one-off cost of basis points, not a recurring drag. If you trade the S&P 500, SPY is the instrument; if you own it, the case for SPY is much thinner.

What to do once you have chosen

Most of what this page describes is invisible on a brokerage statement. Fund-level withholding never appears anywhere — it is deducted before the fund is paid — and 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 SPY from before a move to Europe, or a mix of US and Irish wrappers accumulated across brokers, that is precisely the case it is built for.

Limitations

• The example is an illustration, not your portfolio. The 1.3% yield is an assumption; index yields, fees and share classes move.
• 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.
• Fund data ages. TERs, distribution policies and listings are as published by the issuers in September 2026 — the current factsheet is the authority, not this page.
• Not advice. This is an informational comparison of fund structures, not a recommendation to buy or sell any of them. See the investment & tax disclaimer.