Global Daily Tax News, Ireland Updates Capital Acquisitions Tax Guidance, (Apr 6, 2026)

The Irish Revenue has updated its guidance on Business Relief under the Capital Acquisitions Tax regime.

Sections 90 to 101 of the Capital Acquisitions Tax Consolidation Act (CATCA) 2003 provide for the relief. CAT Manual Part 10: Chapters 2 and 2A - Business Relief, which provides guidance on the operation of this relief, has been updated and refreshed throughout.

In particular, the guidance incorporates amendments included in the 2025 Finance Act to Sections 100 and 101 of the CATCA 2003. In addition, new examples have been added to reflect the changes to the relief.

Business Relief provides relief from CAT for gifts and inheritances of qualifying business property.

In determining the value of a gift or inheritance that qualifies for business relief, Section 100 requires that certain assets, including "excepted assets", must be excluded from the calculation. An asset is an "excepted" asset if it is not used wholly or mainly for the purposes of the business concerned for a two-year period prior to the date of the gift or inheritance.

The Act amended Section 100 to provide that, in addition to this test, an asset will not be an excepted asset if, at the date of the gift or inheritance, it was required to be used for a specific purpose of the business concerned within the following six-year period.

Further, Subsection (1)(b) amended Section 101 to provide that where property on which business relief has been claimed is disposed of, the relief will be withdrawn to the extent that the full proceeds from the disposal are not used, within a year after the disposal, to acquire other qualifying property.

Where the property is disposed of for less than full consideration, the "full proceeds" will be deemed to be equal to its market value immediately before the disposal.