Based on my understanding of CAT, it’s the recipient of the money who would need to redomicile, not just the individual passing on the inheritance. So we’re not necessarily talking about people with lots of money, we’re talking about relatives of people with lots of money.
Add in that in Ireland there’s a lot of very wealthy people who don’t really see themselves as such because it’s all tied up in a PPR.
People typically receive inheritance at roughly age 50-60. Often peak career stage, maybe kids finishing out school/college. So these people would need to take a good guess at when their parents are going to die, move themselves & family to a different country and wait for that dreaded/glorious day to come….all to save 33% on money over a very generous threshold. These people must also be happy paying 52% on earned income to be here in the first place.
Throw in that you retain ‘ordinary residence’ for 3 years after leaving so you need to be gone out of Ireland for at least 3 years before the big day…easier to structure if it’s a gift before death but still a sizeable commitment and requires the parent to be willing to part ways with a substantial part of their wealth before death.
I think you’re talking mega levels of wealth to make all of that worthwhile…and even at that, would you really uproot your family to get €100m instead of €67m?
And in any case. Very wealthy people are masters at avoiding tax anyway. Doesn’t mean the taxes shouldn’t exist. Extreme cases make for bad policy.