Gifting money to a daughter tax resident in Germany.

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My daughter is tax resident in Germany.

The German gift tax rules allow tax free gifts of up to 400,000 euro from a parent to a child in every time period of 10 years.

I am planning on gifting her 250,000 euro.

If she was to return to live in Ireland at sometime in the future would this gift effect her Irish lifetime CAT allowance ?

Would her Irish CAT allowance then be 335,000 euro or 85,000 euro ?
 
85,000 euro - no matter whether she returns to Ireland or not

CAT would be due as the disponer, you, lives in Ireland
 
I think logically whether she lives in Ireland or not, if you were to die your estate is subject to Irish law and if she was the beneficiary she would need to say she already received 300K of her Irish CAT allowance. So why not give her the €300K now and let her worry about CAT tax after you die.
 
If she was to return to live in Ireland at sometime in the future would this gift effect her Irish lifetime CAT allowance ?
Yes, net of the €3,000 annual small gift exemption and the extent to which you can utilise that directly or by proxy.
Would her Irish CAT allowance then be 335,000 euro or 85,000 euro ?
Depends on the threshold at the time.
 
Depends on the threshold at the time.
It’s reasonable to assume that CAT thresholds will be higher in a few decades time.

Even if not in the meantime your daughter will have the benefit of the wealth so it makes sense to transfer sooner so it grows in her name and not yours.
 
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