Maeve O'Connell (Dublin Rathdown, Fine Gael)
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33. To ask the Minister for Finance if he will commence a review of the inheritance tax valuation date payment model (details supplied); and if he will make a statement on the matter. [15835/25]

Paschal Donohoe (Dublin Central, Fine Gael)
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Capital Acquisitions Tax (CAT) is the tax that applies to gifts and inheritances in Ireland. CAT is payable by the beneficiary of a gift or inheritance.

The date of a gift is normally the date it is received. The date of an inheritance is usually the date of death of the person leaving the inheritance. These dates determine the CAT rates and the Group thresholds that apply. However, the date by which CAT is payable is determined by reference to the “valuation date” of a gift or inheritance.

Section 30 of the Capital Acquisitions Tax Consolidation Act (CATCA) 2003 contains the rules for determining the valuation date. The valuation date depends on the circumstances particular to a case and is not a fixed date in relation to all gifts and inheritances. In the case of an inheritance, it is the date on which the executors of the will become entitled to retain the property for the benefit of a beneficiary. Generally, this is the date on which probate or administration is granted, but in some circumstances, it can be earlier or later than this date.

In accordance with section 46 CATCA 2003, where the valuation date occurs between 1 January and 31 August, CAT is payable by 31 October in the same year, and where it occurs between 1 September and 31 December, CAT is payable by 31 October in the following year. Therefore, in circumstances where the valuation date in relation to property comprised in an inheritance falls on 31 August, any CAT that is payable on the inheritance must be paid by 31 October in the same year.

CATCA 2003 makes provision for payment of a CAT liability in instalments in certain circumstances. For example, where a benefit consists of real property, taxpayers have a statutory entitlement to pay the CAT liability by instalments.

Monthly instalment payments for up to 5 years may be allowed subject to the payment of interest at an annual rate of 8%. A lower rate of interest applies where the benefit consists of “agricultural property” or “relevant business property”, as defined in CATCA 2003. In addition, I am advised by Revenue that it may allow payment of CAT by instalments over a longer period in exceptional circumstances where the tax cannot be paid without excessive hardship. In such circumstances, Revenue may allow payment to be postponed for such period and on such terms as appropriate. Revenue will consider each case on its merits, taking into account both the financial circumstances of the beneficiary and the nature of the gift or inheritance involved.

In view of these provisions, I do not currently have plans to review the CAT valuation date payment model.