# Transfer of funds from inheritance



## zsuzsa (7 Jan 2020)

Hi all. I inherited property abroad worth approx 180k 5 years ago and it's only just sold. My CAT bill was 0 as I was below the threshold. I am now going to be transferring the proceeds of sale into Ireland and I didn't make any extra money so don't owe any CGT. I know the bank or credit union have a threshold above which they notify the Revenue, or something. Do I need to be prepared for an audit, or some sort of official return to be made when the money is transferred? I am doing my PAYE Form 16 online now so it's just occurred to me, but I did declare it all properly 5 years ago.


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## NoRegretsCoyote (7 Jan 2020)

You will likely be asked for proof of the origin of funds by the receiving bank in Ireland. This is an obligation on the bank for money laundering purposes. They will notice this even if you split it into smaller amounts and transfer day by day.

I would try and assemble a file showing evidence of the sale, the sale price, and that you were the beneficiary of the will.

This is separate to tax. Maybe someone else can advise.


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## EmmDee (7 Jan 2020)

zsuzsa said:


> Hi all. I inherited property abroad worth approx 180k 5 years ago and it's only just sold. My CAT bill was 0 as I was below the threshold. I am now going to be transferring the proceeds of sale into Ireland and I didn't make any extra money so don't owe any CGT. I know the bank or credit union have a threshold above which they notify the Revenue, or something. Do I need to be prepared for an audit, or some sort of official return to be made when the money is transferred? I am doing my PAYE Form 16 online now so it's just occurred to me, but I did declare it all properly 5 years ago.



They don't notify revenue. Banks have an obligation to monitor for unusual or suspicious activity and if they do think something is unusual to report to / notify the police - as potential money laundering. Banks will work out their own flags for unusual activity but certainly cash lodgements over €10k would be a common one. They also tend to monitor activity versus historic activity. Once reported, it doesn't necessarily mean it will lead to any action - it's just that the Guards could investigate.

However, if you have background for an unusual transaction and can explain the source of funds, they generally won't report it. Personally I would get on to the bank and advise them that you will be paying this in and the source of the funds and ask them to have it on file - if they need backup they can ask you. In addition, if it is coming from an account at a regulated bank in a "regular" jurisdiction, it will have less concerns for them. Even better if coming from an account in your name.


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## zsuzsa (7 Jan 2020)

Thank you. It will be coming from my own Transferwise account. That's a good idea, to have the file ready for the bank and notify them in advance. Sadly I have no such history of large transfers! But I will get onto the branch manager in advance with the sale documents.


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## Gordon Gekko (7 Jan 2020)

I received a substantial sum into Ireland last year and the bank did not contact me. As I understand it, Revenue’s REAP system will receive details of the transfer and then cross-check it against my tax return for the period.


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## torblednam (7 Jan 2020)

The bank don’t want, and have no interest in, a file. That’s not their job. They’ll have a policy and procedures that they’ll follow, in order to comply with money laundering regs. 

Even though you can show them a file that shows the source of the money, they’re not Revenue and aren’t in a position to confirm whether you’re tax compliant or not.

If you want to avoid any potential for a tax audit (which is probably remote enough anyway) and put your file to good use, you should file a CGT return in due course, detailing the disposal, albeit with nil tax payable. That would enable Revenue to see the source of your substantial lodgement to the bank and obviate the need for any enquiries.


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## NoRegretsCoyote (7 Jan 2020)

There are two issues being conflated here:


Tax 
Money laundering


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## EmmDee (7 Jan 2020)

NoRegretsCoyote said:


> There are two issues being conflated here:
> 
> 
> Tax
> Money laundering



+1

I don't work in retail banking but do work in institutional side (so I may be uninformed from a retail point of view) but banks are concerned with (2) not (1)


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## NoRegretsCoyote (7 Jan 2020)

torblednam said:


> The bank don’t want, and have no interest in, a file. That’s not their job. They’ll have a policy and procedures that they’ll follow, in order to comply with money laundering regs.



I have very recently transferred a six-figure sum from a bank in Ireland to one abroad.

The recipient bank wanted to know source of funds (a house sale) and was quite happy when I provided them with paperwork concerning the sale.

I doubt it works much different in reverse, as AML obligations on banks within the EU are reasonably similar.


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## RedOnion (7 Jan 2020)

OP asked about tax. That's answered.

Anybody who knows anything about AML practices will know it's a criminal offence to explain to anyone how to circumvent them, so therefore they can't explain how they work.

As @torblednam noted, no bank wants a file.


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## torblednam (7 Jan 2020)

NoRegretsCoyote said:


> I have very recently transferred a six-figure sum from a bank in Ireland to one abroad.
> 
> The recipient bank wanted to know source of funds (a house sale) and was quite happy when I provided them with paperwork concerning the sale.
> 
> I doubt it works much different in reverse, as AML obligations on banks within the EU are reasonably similar.



I’m not sure what you mean by them being “quite happy when I provided them with paperwork” - they were following procedures when they asked you about the source of the funds, and they will have continued to follow procedures subsequently. That may (or may not) have involved them completing a report that would be transmitted to the relevant body / bodies.


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## EmmDee (7 Jan 2020)

RedOnion said:


> OP asked about tax. That's answered.
> 
> Anybody who knows anything about AML practices will know it's a criminal offence to explain to anyone how to circumvent them, so therefore they can't explain how they work.
> 
> As @torblednam noted, no bank wants a file.



Nobody's discussing circumventing anything. There are explanations on what banks have to check - for AML not tax reasons 

(and torblednam is incorrect - a bank may be interested in a file. Hence the suggestion to explain to them and if they want backup they can ask for it)


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## NoRegretsCoyote (7 Jan 2020)

torblednam said:


> I’m not sure what you mean by them being “quite happy when I provided them with paperwork” - they were following procedures when they asked you about the source of the funds, and they will have continued to follow procedures subsequently. That may (or may not) have involved them completing a report that would be transmitted to the relevant body / bodies.



Unlikely, they emailed me back to say "_everything is fine ! With  your documents and your cooperation the compliance department could close the file._" I have heard no more from them since.




RedOnion said:


> Anybody who knows anything about AML practices will know it's a criminal offence to explain to anyone how to circumvent them, so therefore they can't explain how they work.
> 
> As @torblednam noted, no bank wants a file.



Semantics perhaps, but I recently provided a bank with a 20-page pdf of scans of documents relating to a house purchase. This explicitly satisfied their compliance department, see above.

Central Bank [broken link removed]also say:



> Firms should put in place adequate policies and procedures to identify unusual transactions or patterns of transactions. *Examples may include transactions or patterns of transactions that are:  Larger than the Firm would normally expect based on its knowledge of the customer*, the business relationship or the category to which the customer belongs;  *Of an unusual or unexpected pattern compared with the customer’s normal activity *or the pattern of transactions associated with similar customers, products or services; or  Very complex compared with other similar transactions associated with similar customer types, products, or services; and the Firm is not aware of an economic rationale or lawful purpose or doubts the veracity of the information it has been given. *Where Firms detect unusual transactions or patterns of transactions, they should apply EDD measures sufficient to help the Firm determine whether these transactions give rise to suspicion. Such EDD measures should at least include:  Taking reasonable and adequate measures to understand the background and purpose of these transactions, for example by establishing the source and destination of the funds* or finding out more about the customer’s business to ascertain the likelihood of the customer making such transactions; and




To conclude: it's not unlikely that the OP will be asked to prove source of funds, and it would be wise to have paperwork ready.


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## RedOnion (7 Jan 2020)

NoRegretsCoyote said:


> Semantics perhaps, but I recently provided a bank with a 20-page pdf of scans of documents relating to a house purchase.


Before or after the transaction?


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## NoRegretsCoyote (7 Jan 2020)

RedOnion said:


> Before or after the transaction?



About two thirds of the way through. I was doing it in €10k increments.


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## RedOnion (7 Jan 2020)

NoRegretsCoyote said:


> About two thirds of the way through. I was doing it in €10k increments.


Sorry, I didn't realise context of my comment wasn't clear. 
There's no point giving a file to a bank in advance. A copy will sit in a branch. Then there's an automatic transaction, with largely automated monitoring. The computer doesn't look in the drawer in the branch. If the bank has questions, as in your case, they'll ask for it.

There are over 20,000 suspicious transition reports annually in Ireland. You wouldn't know whether or not a transaction had been reported. Mainly because it's illegal to tell you.


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## NoRegretsCoyote (7 Jan 2020)

RedOnion said:


> Sorry, I didn't realise context of my comment wasn't clear.
> There's no point giving a file to a bank in advance.



I never suggested that. I said that the OP should have it ready in case the bank asks. There is a risk that the funds could be blocked until source of funds can be shown. I know a little about AML procedures and had my own paperwork ready. These requests could take some people by surprise and it could take them a while to track down documents, particularly if it relates to transactions some time ago.



RedOnion said:


> There are over 20,000 suspicious transition reports annually in Ireland. You wouldn't know whether or not a transaction had been reported. Mainly because it's illegal to tell you.



Agreed, I only said it was "unlikely".

I have no inside knowledge, but the Garda Economic Crime Bureau is likely to push back against banks who set the threshold too low for filing STRs.

20,000 is indeed a big numerator, but what is the denominator?


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## RedOnion (7 Jan 2020)

NoRegretsCoyote said:


> I never suggested that.


We're miscommunicating. 
You weren't the person who suggested contacting bank in advance, and it wasn't your comment I had intended to reply to, but I can see how you thought it was.



NoRegretsCoyote said:


> but what is the denominator?


It's a very big number!!   

There's an inconsistency in reporting across both institutions and countries.
Until recently in Germany for example a bank had to have evidence to report a transaction, whereas here the obligation was to report if there was a reasonable suspicion. Some consistency brought about with the latest EU directive, but there still isn't a single standard.


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## zsuzsa (8 Jan 2020)

Ok thanks all. Yes I can confirm I am not looking to circumvent anything. All is above board with my CAT declaration and return.
Soooo... It's the banks, not necessarily the Revenue, who may flag the transfer and I should have the documents relating to the sale ready in case the bank looks for it, is my summary of the above?


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## noproblem (8 Jan 2020)

zsuzsa said:


> Soooo... It's the banks, not necessarily the Revenue, who may flag the transfer and I should have the documents relating to the sale ready in case the bank looks for it, is my summary of the above?
> 
> I would have thought it wouldn't be the banks looking for it at all.


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## zsuzsa (9 Jan 2020)

Sigh! Ah well I have been looking at the Transferwise conditions (as I will be moving the money to that account for best exchange rate to Euro first) and THEY will want proof of proceeds of sale under Anti Money Laundering legislation, so if BOI/Revenue/Man on the moon comes looking for it, it'll be there! 

I think my initial worry was - I inherited this in 2015, now I get the money in 2020, do I need to let Revenue know, does it actually matter when the money is transferred , but I guess I will find out!


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## RedOnion (9 Jan 2020)

zsuzsa said:


> Transferwise conditions (as I will be moving the money to that account for best exchange rate to Euro first) and THEY will want proof of proceeds of sale under Anti Money Laundering legislation


Of course, they're a regulated entity. (One if the reasons your bank won't want a file...).

Look, you've nothing to worry about. You declared the inheritance. There was no tax due. Now you're transferring money.
There might be a few questions, but you already have the answers. Someone might have a question - they'll tell you exactly what they need then. It could be a verbal confirmation, or a letter from a foreign solicitor translated and apostilled. Nobody knows what'll be needed, but since everything you're doing is completely legitimate, then just go ahead and do it.


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## zsuzsa (8 Apr 2020)

Hi all I just thought I would update this - I transferred a substantial amount of money from Eastern Europe to my transfer wise account. It arrived the next day from the sender. Then, I converted it to Euro for really a small fee (0.55%)  and sent it to my Euro account here for 69 cent. It arrived the same day, I was very surprised at how easy it was. I have not had any enquiries from Transferwise or my bank here about the sum but I have deeds of sale, translated grant of probate and  copy of the bank transfer all ready if they do ask. Compared to my previous experience with Revolut, money being blocked for much smaller amounts and dealing with help bots to much frustrationI really would recommend Transferwise.


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## Vanessa (20 Apr 2020)

Revenue are not as bad as they are painted. Once you have your paperwork write there wont be a problem. I dont see why an audit would necessarily arise.
The Banks may ask for proof of source for thefunds which should not cause difficulty


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## Baby boomer (11 May 2020)

I have a couple of clients in the Eurozone area for whom I occasionally do some work. For various reasons they pay me via SEPA transfer to a separate KBC account that I use for those customers only.  I then transfer the money directly to my main business account as soon as I'm aware it's arrived in the KBC account.  A few months ago a few payments happened to arrive within a couple of days of each other and I transferred the money out the same day.  Got a call from KBC asking me what the payments were for and why I had transferred the money.  He was extremely polite and almost apologetic for asking but was more than happy with the explanation.  It just struck me as a very odd thing to ask.  The sums were all in the region of 1k to 3k - hardly enough to trigger an inquiry, I'd have thought.  Unless I'm on a watchlist!!


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