Prior gifts and CAT aggregation

A daughter receives €300,000 from her father's estate in 2026. On its own, the inheritance is well within the Group A threshold of €400,000 and no CAT is due. But in 2008 she had received a €150,000 gift from her mother to help buy her first house. Because both parents are Group A, the gifts aggregate: €150,000 + €300,000 = €450,000 lifetime. She crosses the threshold by €50,000. CAT on the excess: €16,500.

Revenue's records go back to 1991. They cross-reference IT38 filings against SA2 filings, and against its own historical CAT returns. Aggregation cannot be avoided by forgetting a prior gift; Revenue will find it.

What aggregation means

Every gift or inheritance received from any donor or deceased person in the same CAT Group counts towards a single lifetime threshold for that Group. The three Groups are:

• Group A: parents, stepparents, adoptive parents, foster parents (as donors); receiving child or equivalent (as beneficiary). Threshold: €400,000 lifetime.
• Group B: siblings, aunts, uncles, grandparents, grandchildren 18+. Threshold: €40,000 lifetime.
• Group C: all other relationships. Threshold: €20,000 lifetime.

Gifts within the same Group across a lifetime add up. Gifts across different Groups do not add up: each Group has its own separate threshold. A beneficiary who has received €350,000 from their parents (Group A) and €35,000 from their aunt (Group B) has used €350,000 of the €400,000 Group A threshold and €35,000 of the €40,000 Group B threshold. Both are independent.

The 5 December 1991 start date

Aggregation is not truly "lifetime." It starts from 5 December 1991. Gifts received before that date do not count.

For most people making claims today, 1991 is irrelevant in practice, because the beneficiary had not yet inherited anything of consequence at that point. The date matters mainly for older beneficiaries who received significant gifts or inheritances decades ago. A 75-year-old beneficiary today who received a substantial gift from their parents in 1995 must still include that in aggregation.

Exemptions that do not aggregate

Some benefits are exempt from CAT and do not count in aggregation:

• Small Gift Exemption: €3,000 per donor per year, lifetime, is exempt and does not aggregate. A parent gifting €3,000 per year for 20 years gives a total €60,000 outside the aggregation sum.
• Spouse and civil partner exemption: inheritances between spouses are fully exempt and do not aggregate.
• Charity gifts: exempt in the charity's hands, no aggregation issue.
• Wedding gifts from parents to children, within limits: specific exemption for reasonable wedding gifts.

What does count

Everything received from the same Group since 5 December 1991 that is not expressly exempt:

• Cash gifts above the €3,000 annual Small Gift Exemption
• Property gifts (transferring the family home or a share of it)
• Gifts of shares or investments
• Forgiven loans (writing off a loan is a gift at the date of forgiveness)
• Below-market transactions (selling a house worth €400,000 to a child for €200,000 is a gift of €200,000)
• Inheritances on death

Revenue has well-developed case law on each of these categories. A child "buying" a house from a parent at below market value should expect Revenue scrutiny; a forgiven loan is reported on the year of forgiveness, not the year of original lending.

How Revenue checks

Revenue maintains a record of every IT38 ever filed by every person with an Irish PPS number. When a new IT38 is submitted, Revenue cross-checks:

• Earlier IT38s from the same beneficiary
• SA2 filings naming the beneficiary as an inheritor
• Capital Gains Tax returns showing dispositions at below-market prices
• Stamp Duty records on property transfers

Beneficiaries who under-declare past gifts are routinely caught. The typical pathway: beneficiary files an IT38 today; Revenue matches against an earlier IT38 that shows a prior gift; query is raised; additional CAT plus interest plus penalty is assessed.

Penalties for under-declared CAT can reach 100% of the understatement in serious cases. In practice, a good-faith error gets a reduced penalty; a deliberate omission gets the full penalty.

Valuations on old gifts

One practical question: at what value does a 2008 gift of shares appear on a 2026 IT38? The answer: the value at the date of the original gift, not the value today.

A 2008 gift of shares worth €50,000 that are now worth €120,000 enters the aggregation at €50,000. The beneficiary does not get a discount for inflation; they do not get a top-up for appreciation. The original valuation stands.

This is why keeping records matters: the beneficiary needs the 2008 valuation (from the share registrar or the 2008 IT38 itself if one was filed).

Worked example

A son has received the following from his parents over his lifetime:

• 1998: €25,000 towards university costs
• 2005: €50,000 towards buying his first house
• 2015: €60,000 when his father gifted him shares in the family business (valued at gift date)
• 2026: inheritance of €280,000 on his mother's death

All four are Group A. Aggregation:

• Cumulative benefits: €25,000 + €50,000 + €60,000 + €280,000 = €415,000
• Group A threshold: €400,000
• Small Gift Exemption offsets: each of the prior gifts already exceeded €3,000, so the exemption only shelters €3,000 from each year's contribution (not the full gift). Minimal impact here.
• Taxable excess: €15,000
• CAT at 33%: €4,950

Without aggregation, the €280,000 inheritance on its own would not have triggered any CAT. With aggregation across his lifetime, a small charge arises.

Record-keeping for beneficiaries

If you have received significant gifts from family, keep records:

• Bank statements showing the receipt
• Letters from the donor confirming the gift
• Any IT38 filings you made at the time (even below threshold)
• Share registrar valuations at the gift date
• Property valuations at transfer date

Records should be kept for 20+ years. Revenue's lookback is effectively lifetime (since 1991), and the burden is on the beneficiary to produce evidence of original values.

When professional advice helps

Simple aggregation (a handful of clearly-documented prior gifts) can be handled on the IT38 without professional help. Retain a tax adviser where:

• Aggregation totals approach or exceed the threshold
• Any prior gift's valuation is uncertain or disputed
• There are below-market transactions that might be partly gift and partly sale
• A previous CAT filing was made against a different threshold or Group
• There is a family business or farm with a history of part-disposal gifts