Receiving an inheritance from abroad does not automatically place it outside the Irish tax system. Equally, an overseas asset is not taxed in Ireland simply because money is later transferred into an Irish bank account. The underlying connection with Ireland must be examined.
Capital Acquisitions Tax can be relevant through the residence or ordinary residence of the disponer or beneficiary, or through the location of the property. Domicile and special rules for people with a foreign domicile can affect the analysis.
Gather the facts first
Record where the deceased lived, where you live, the relevant residence history and where each asset is situated. Citizenship, residence and domicile are different concepts. A passport alone does not settle every tax question.
Keep the foreign will, estate accounts, valuations and any tax assessments. Ask for an explanation of what a foreign tax charge relates to rather than assuming that a familiar label has the same meaning as Irish CAT.
Consider double taxation
Two countries may tax the same event or property under different systems. A treaty or unilateral relief may reduce double taxation where its conditions are satisfied. Relief is not necessarily a refund of every foreign charge.
Revenue's unilateral relief guidance, for example, imposes limits and requires the relevant connection between the Irish charge and foreign tax. The calculation may depend on the property and the tax actually paid. Obtain advice before assuming that the foreign estate's payment settles your Irish position.
Keep succession and tax separate
A foreign probate process may establish who receives an asset without resolving the beneficiary's Irish CAT obligations. You may still need to file an Irish return or retain records supporting an exemption, credit or conclusion that no charge arises.
Currency conversion, valuation dates and the timing of foreign assessments can introduce additional practical issues. Start gathering information early rather than waiting until all overseas administration is complete.
If you are planning your own estate with assets in more than one country, coordinate the wills and tax advice. A well-intended foreign will can conflict with an Irish document if the arrangements are prepared independently.
Cross-border inheritance is an area where individual advice is particularly valuable. A clear factual record allows an adviser to distinguish the tax that is genuinely due from a charge that may be relieved or does not apply.
Sources and further reading
General information, not advice on your individual circumstances. Laws and tax rules can change; check the linked official guidance and obtain professional advice where needed.
