BorderFolio/US ETF vs UCITS calculator
US ETF vs UCITS ETF calculator
Rates from IRS Table 1 (Rev. May 2023) · last reviewed 3 September 2026
The same holdings, two wrappers, two different leaks. A US-domiciled ETF is cheaper to run but its whole distribution is taxed at your residence's treaty rate; an Irish UCITS costs more per year but suffers only 15% on the US-source share of its dividends. Which leak is larger is arithmetic, not opinion — set your residence and a fund below and see it on your own numbers, in dollars per year.
This calculator needs JavaScript. Without it, the mechanics are worked through in prose in US ETFs vs Irish UCITS, and the rate for every residence is listed on the country table.
What this compares
A US-domiciled fund pays no US tax on the US dividends it receives, but its distribution to you is US-source income: your residence's rate from the IRS treaty table is applied to the entire payout, non-US holdings included. An Irish UCITS holding the same stocks suffers 15% US withholding inside the fund, on the US-source dividends only, under the US–Ireland treaty — and Ireland withholds nothing further from a non-resident. So the tax comparison is your treaty rate on everything against 15% on the US slice. The fee comparison runs the other way: the US wrapper is almost always cheaper, and the fee is charged on your whole position, not just the income. The full mechanics are here — this page just runs the two totals on your numbers.
Why the fund preset changes the answer
A low-yield fund is decided by fees. A Nasdaq-100 tracker yielding 0.6% throws off $600 a year per $100,000 — even the full 30% of that is $180, while a 13-basis-point fee gap on the same position is $130 every year regardless of paperwork. At a 15% treaty rate the withholding difference shrinks to almost nothing and the cheaper wrapper simply wins.
A high-yield fund is decided by withholding. A dividend ETF yielding 3.5% pays out $3,500 a year on the same position, and every percentage point of withholding rate is now $35. For a 30%-rate residence the gap between the wrappers runs to hundreds of dollars a year, and no realistic fee difference catches up.
A global fund is decided by the US-source share. The UCITS's 15% applies only to the US-source part of the dividend — roughly 40% of it for a total-world index, because non-US holdings yield more — while the US fund's treaty rate hits the whole distribution, Japanese and European dividends included. That asymmetry is why the global case favours the UCITS more strongly than the headline rates suggest.
Two residences are worked through in full rather than left to the form: Irish-domiciled ETFs from India, where the treaty rate is 25%, and from South Africa, where it is 15% and the fee gap does more of the work.
What this cannot see
- Your actual statement. This is the treaty table rate. What your broker withheld is on your statement, and the two differ most often because documentation was missing or expired.
- Eligibility. The IRS table itself cautions that it is not a comprehensive guide to eligibility for a treaty rate; limitation-on-benefits provisions and the treaty text govern.
- Tax at home, and credits. The second layer — tax where you live — is not modelled, and neither is a foreign tax credit. A residence that grants credit for withholding can absorb much of the US fund's disadvantage; one that taxes nothing cannot.
- Deemed-tax regimes. Several residences tax accumulating funds on an imputed basis rather than on cash received, which can change the effective cost of a UCITS wrapper in ways no per-year drag figure captures.
- Estate exposure is not a per-year number. The estate note below the result is a flag, not a cost. Whether it ever bites depends on how the assets are held and on the circumstances of an estate.
- This is not advice. Confirm anything material with a qualified adviser in your jurisdiction.
Common questions
How do I compare a US ETF with a UCITS ETF?
Put the two annual costs of each wrapper side by side. For a US-domiciled ETF: your residence's treaty rate applied to the whole distribution, plus the fund's expense ratio on the whole position. For an Irish UCITS on the same holdings: 15% US withholding suffered inside the fund on the US-source share of the dividends only, plus the higher TER on the whole position. Whichever total is smaller leaks less per year — and which one that is depends on your treaty rate, the fund's yield, its US-source share and the fee gap, which is exactly what this calculator computes.
Is a UCITS ETF always better for non-US investors?
No. The UCITS wins on withholding only where your treaty rate is above the 15% it suffers inside the fund, and its higher TER is charged on your whole position, not just on the income. A low-yield fund such as a Nasdaq-100 tracker throws off so little dividend that the fee gap decides the comparison; a resident of a 10% treaty country loses more inside the UCITS than at the broker. Estate exposure and availability under PRIIPs can also settle the question before either number matters.
Does the calculator include tax in my own country?
No. It computes only the first layer — what is taken by the United States before or as the dividend reaches you — plus the fund fee. Tax in your country of residence is a separate second step, and it interacts with the wrapper choice: withholding taken from a distribution paid to you can often be credited against tax at home, while the 15% suffered inside a UCITS generally cannot. Credits are not modelled here.