Ms Lorna Gallagher:

The valuation date is dealt with in section 30 of the Capital Acquisitions Tax Consolidation Act 2003, CATCA. There are various iterations in that provision, which is about a page long, setting out when the valuation date crystallises depending on the facts and circumstances of the passing of the deceased. The short answer is that it depends on a given case when the valuation date will crystallise. I appreciate the Senator's point. Crystallisation of that date is a significant event in itself in terms of payment of tax.