Resident abroad & implications on tax payable on inherited Irish estate

fry_joanne

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I am resident in another EU country (Denmark) and am in the process of inheriting an estate from a deceased parent (Irish citizen) who has been resident in Ireland. I am currently uncertain as to the tax implications of me being resident in another country. It is not clear to me if I will incur

i) CAT on the estate (on amounts above the specificed tax-free limit) only
ii) Inheritance tax ("boafgift") in Denmark only
iii) Or both

Reading some articles so far, it would suggest that the tax payable is based on the country of residence of the deceased (i.e., in this case, Ireland). Am I therefore liable to pay Irish CAT only? There does not appear to be any formal double-taxation treaty between the two countries (as there is with e.g., UK and US). Could this mean that I am also liable for tax in Denmark?

Any input is much appreciated.
 
As your parent was not resident in Denmark and the property is not in Denmark then I would assume based on PWC advice (I cannot post the link) you would not be liable to Danish estate (inheritance tax). But you would potentially be liable to Irish CAT of 33% on any sum exceeeding 310,000 euro as the property was located in the Republic of Ireland (assuming no prior gifts/inheritances from a parent in Ireland and the parent died after 12 October 2016).

'Inheritance received by a Danish resident from an individual who was not resident in Denmark prior to death is not subject to Danish estate tax except if the inheritance consists of property located in Denmark or of assets related to a PE in Denmark'
 
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