The article “Are mutual fund fees tax deductible?” was originally published in MoneySense on April 24, 2023. Photo by Centre for Ageing Better from Unsplash.

Don’t go claiming a deduction for mutual fund fees on your tax return. Why? Because they’ve already been indirectly deducted.

“Are management fees within a mutual fund in a non-registered account deductible as carrying charges on my tax return?” – John

Tax treatment of mutual fund fees

The Canada Revenue Agency (CRA) allows taxpayers to claim carrying charges, interest expenses and certain other investment expenses as a tax deduction on line 22100 of a tax return. This includes fees paid for investments to be professionally managed, fees for certain investment advice, interest on money borrowed for certain investment purposes, and in some cases, fees to prepare a tax return.

However, to answer your question, John, mutual fund fees cannot be deducted on your tax return. Fees paid to an investment advisor who manages your investments, excluding commissions paid to buy and sell investments, are generally deductible. The deductibility of fees is limited to taxable, non-registered accounts, so it does not apply to registered accounts like registered retirement savings plans (RRSPs) or tax-free savings accounts (TFSAs).

Why mutual fund fees aren’t deductible on your tax return

Commissions to buy and sell investments factor into the calculation of capital gains and losses for a non-registered account, so there is some tax benefit. The commissions paid to buy and sell increase the adjusted cost base or reduce the proceeds of disposition accordingly.

Investment advisors may promote the tax deductibility of investment counsel or management fees as being a significant benefit of a fee-based account, where an investor pays a percentage of their assets in fees each month or each quarter. While these fees may be directly tax deductible on line 22100 of your tax return, the fees paid for a mutual fund are indirectly tax deductible.

This is because mutual funds flow through their net income to the fund’s unit holders. Net income is calculated by taking gross income, like interest, dividends and realized capital gains, and deducting expenses, including management fees. Mutual fund fees tend to be in the 2% range, but there are low-cost funds available.

A fee-based account may result in an investor paying lower fees than a traditional mutual fund, often in the 1% to 2% range. A fee-based account may also better align an advisor’s interests with those of an investor compared to a traditional transactional account. But to say that a fee-based account results in better tax efficiency may not be entirely accurate, since mutual fund fees reduce taxable income anyway.

Tax deductibility of ETF fees and other expenses

Exchange-traded funds (ETFs) have embedded fees like the ones attached to mutual funds, and those fees are not tax deductible directly on your tax return. However, like fees on mutual fund, those paid on ETFs are indirectly tax deductible because they reduce the net income flowed through to ETF investors to report on their tax returns.

Other non-deductible expenses include:

  • Interest on money borrowed to invest in investments that can only earn capital gains
  • Interest on money borrowed to invest in RRSPs, TFSAs, or similar tax-preferred accounts
  • Safety deposit box charges (you used to be able to many years ago, so some people forget this)
  • Subscription fees for financial newspapers, magazines or newsletters (though they may qualify for the digital news subscription tax credit)
  • Fees paid for general financial advice, like financial counselling or planning
  • Fees paid for tax return preparation, unless you were self-employed (reporting sole proprietorship or partnership income) or had a rental property

In summary, John, although you cannot deduct your non-registered mutual fund fees on your tax return, remember that they were already deducted from the net income reported on the T3 slip you claim on your tax return.

Jason Heath is a fee-only, advice-only Certified Financial Planner (CFP) at Objective Financial Partners Inc. in Toronto. He does not sell any financial products whatsoever.