You have received a gift, or you are dealing with an inheritance. Do you need to file a Capital Acquisitions Tax (CAT) return, and when is it due? These are the questions to answer first. The small gift exemption CAT rule may remove a modest gift from the calculation, but it does not set the filing date for a larger gift or an estate.
For many people facing a CAT deadline in Ireland in 2026, the key date is 31 October 2026. Some beneficiaries can use an extension to 18 November 2026, but only if they meet Revenue’s online filing and payment conditions. The correct date depends on the valuation date of the gift or inheritance, and a return can be required even when no tax is payable. This guide explains the sequence.
First, check whether a CAT return is required
CAT is a tax on gifts and inheritances. The beneficiary, meaning the person who receives the benefit, must consider its taxable value alongside earlier taxable gifts and inheritances received under the same relationship group. Previous benefits since 5 December 1991 generally count towards the relevant group threshold.
At the time of writing, the CAT thresholds are €400,000 for Group A, €40,000 for Group B and €20,000 for Group C. The correct group depends on the relationship between the person giving the benefit and the beneficiary. A parent-to-child benefit generally comes under Group A. CAT is currently 33% on taxable value above the available threshold.
A return may be due before any tax is due. Revenue generally requires an IT38 return if the current benefit, combined with previous taxable benefits in the same group, exceeds 80% of that group’s threshold. For a beneficiary using the current Group A threshold, 80% is €320,000. Some claims, including agricultural or business relief, require a return even where the 80% test is not met.
For example, a daughter who has received no earlier Group A benefits inherits €350,000 from a parent. She is below the €400,000 Group A threshold, so on these facts no CAT is payable. She has, however, exceeded €320,000 and must file a return. Waiting until a tax bill arrives would put her at risk of missing the filing date.
What is the CAT pay and file deadline?
The deadline follows the valuation date: the date used to value the gift or inheritance for CAT. A gift’s valuation date is generally the date it is received. For an inheritance, the valuation date can be later than the date of death, depending on when the beneficiary becomes entitled to the asset and the estate’s administration. Do not calculate an estate beneficiary’s filing date from the date of death alone.
Revenue’s standard pay and file periods are:
| Valuation date | Normal CAT pay and file deadline |
|---|---|
| 1 January to 31 August | 31 October in the same year |
| 1 September to 31 December | 31 October in the following year |
So a taxable gift with a valuation date in July 2026 normally belongs to the filing period ending 31 October 2026. One with a valuation date in December 2026 normally belongs to the period ending 31 October 2027. The same date rules apply to an inheritance once its valuation date has been established.
The 18 November 2026 ROS extension
Revenue has extended the 2026 deadline to Wednesday, 18 November 2026 for beneficiaries with gifts or inheritances whose valuation dates fall in the year ended 31 August 2026. To qualify, the beneficiary must both file the CAT return and make the appropriate payment through ROS. If only one action is completed through ROS, the ordinary 31 October 2026 deadline still applies. The extension does not bring a December 2026 valuation date into the 2026 filing period.
If you are dealing with probate, establish each beneficiary’s valuation date and previous taxable benefits early. An executor may help provide valuations and estate records, while the beneficiary must ensure their CAT position and any return are addressed. Where an asset or entitlement is complex, obtain advice on the valuation date rather than guessing which October applies.
Does the small gift exemption CAT rule change the deadline?
The annual small gift exemption allows a person to receive the first €3,000 in gifts from each giver in a calendar year free of CAT. Exempt gifts do not use up the recipient’s group threshold, and a CAT return is not required just to claim the exemption for annual gifts of up to €3,000.
If two parents each give their son €3,000 in 2026, he receives €6,000 but has a separate €3,000 allowance from each parent. Those gifts alone do not create an IT38 filing obligation. If his mother gives him €5,000 instead, €3,000 is exempt and the remaining €2,000 must be considered with other taxable Group A benefits. This does not necessarily mean tax or a return is due: check his cumulative position against the threshold and 80% filing test.
The annual gift limit runs to 31 December. A transfer received in January 2027 is ordinarily a 2027 gift, even if the giver intended to make it in December 2026. Missing 31 December means losing the opportunity to use an unused 2026 gift allowance; it is not itself a late-filing penalty. The CAT pay and file date, if a return is needed, is a separate question based on the valuation date.
What if the giver has died?
The small gift exemption ordinarily applies to gifts, not bequests under a will. An executor cannot reduce a beneficiary’s inheritance by allocating €3,000 to the deceased person’s unused annual gift allowance.
There is a specific exception for a genuine lifetime gift that becomes an inheritance for CAT because the giver dies within two years of making the disposition. Section 69(3) preserves the small gift relief if that earlier gift otherwise qualified. Keep the transfer records so the gift can be distinguished from the later inheritance.
Spouses and civil partners have a separate CAT exemption for gifts and inheritances between them. The €3,000 rule is not the reason those transfers are exempt. Other reliefs have different conditions; seek advice before assuming that a gift, estate asset or family loan needs no return.
What happens if the CAT filing or payment deadline is missed?
If a required IT38 is filed late, the surcharge is 5% of the CAT due, capped at €12,695, if filed within two months after the deadline. It rises to 10%, capped at €63,485, if filed later. Revenue may also charge daily interest on CAT paid late. Because the surcharge is calculated by reference to tax due, an obligation to file where no CAT is payable should not be confused with an automatic 5% charge; the return can still be overdue.
If a deadline has passed, check the valuation date, earlier benefits, the correct group threshold and the amount payable. Then arrange any outstanding return and payment promptly. If you are unsure whether you qualify for the 2026 ROS extension, work to the 31 October date while you verify the conditions.
What should you do now?
Before the relevant deadline, gather:
- The document showing what was given or inherited, and evidence of when the beneficiary received or became entitled to it.
- A valuation of the asset at the correct valuation date.
- Details of earlier taxable gifts and inheritances within the same group.
- Bank records for any annual gifts, showing the giver, recipient, amount and receipt date.
- Details of any relief you intend to claim and whether it requires an IT38.
These records help determine both whether a return is required and which filing period applies. They are especially useful when family gifts were informal or the person who made them has died.
Contact HOMS Assist to arrange a consultation with our probate and inheritance team. We can review your gifts or estate records, identify the relevant CAT valuation and filing dates, and help you address a return or payment before a deadline becomes a more expensive problem.
This article provides general information as at 23 September 2026. The correct CAT treatment
About the author: Claire Tuohy is a Partner at HOMS Assist, specialising in wills, trusts, probate, and cross-border estates. With dual qualifications in Ireland and England & Wales, and as an active member of the Society of Trusts and Estate Practitioners (STEP), Claire brings deep expertise in tax-efficient succession planning. Her commitment to clear, practical advice ensures high-net-worth clients navigate complex estate matters with confidence.
