CAT for UK payee?

kalooki

Registered User
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12
Due to personal circumstances, a parent is considering liquidating some of their assets and gifting cash to one of their children.

Assume EUR 1.5m value house, three children, the previous intent for the parent's will was to sell and split the 1.5m three-ways after the parent passed...

...but now the plan might change.
The parent is considering selling the house, giving 500k cash to one child, buying a cheaper home for themselves, and then basically rewriting their will to ensure the "other 2/3rds" (whatever that means) goes to the other two kids who didn't get the early payout.

All the kids get along, and the two "others" are happy enough and don't really need to protect their interests, they are liquid, it's not their money, and they are very supportive of the the parents desire to pay the "early bird" even if it is to their long term financial detriment.

So
- It seems pretty clear that assuming the assets were in Ireland and all the people were Irish tax residents the 500k gift would be subject to CAT, with the 335k allowance lifetime, and any residual inheritance for the early bird would be taxed as it's all used up for that person.


But there is an additional complication; the "early bird" child lives (and is resident for all purposes) in the UK, but might be moving back to Ireland in the next few years.

So the questions
1. Am I missing something above?
2. Is there an upside for the "early bird" child getting the 500k now, before they move back to Ireland, so that it doesn't "eat up" their lifetime allowance?
 
Once the disponer lives in Ireland, the gift of € 500k is taxable in Ireland, no matter where the recipient lives

Assuming the recipient has not received any prior gifts from the parents since Dec 1991, then CAT of € 54k would be due
 
The parent should do nothing until the announcement of the 2025 budget next month when the CAT thresholds are expected to significantly increase.
 
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