Inheritance and gifts are where a move can turn expensive.
Here Britain and Ireland both reach for the same estate, and the treaty between them divides less than most people expect. For families with larger wealth this subject belongs before the move.
The Irish side in three sentences
Ireland levies a single tax on inheritances and gifts, Capital Acquisitions Tax. The rate is 33 per cent on everything above the threshold of the relevant group of relatives.
Unlike UK inheritance tax, it is paid by the person who receives, and the thresholds apply over a lifetime, not per gift. For a family moving in, one rule matters above all: a person not domiciled in Ireland is caught by this tax only once they have been resident in Ireland for 5 consecutive years. From year 6, worldwide assets come within Irish reach.
The full Irish side, with the thresholds and the clock, is on our page on the 33 per cent trap. This page answers the other half of the question: what does Britain do, and how do the two meet?
| Group | Relationship | Threshold |
|---|---|---|
| A | parent to child | €420,000 |
| B | brothers and sisters, nieces and nephews, grandchildren, grandparents | €44,000 |
| C | everyone else | €22,000 |
The thresholds apply for life and across everything received within the group. Rate on the excess: 33 per cent.
Source: Statute text on irishstatutebook.ie; Revenue on the thresholds and on credit for double taxation. As of: checked 14 October 2026; thresholds under Financial Resolution No. 2 of 6 October 2026 for benefits taken from 7 October 2026.
There is a treaty, and it is with Britain
For most of Europe, an estate that crosses into Ireland meets no treaty at all: Ireland has only two on inheritance and gift tax, with the United Kingdom and the United States. For British families that is the good news of this page. The convention was signed in London on 7 December 1977. It names the British tax of the time, capital transfer tax, the forerunner of inheritance tax, and it extends itself to any substantially similar tax imposed in its place; Revenue applies it to UK inheritance tax today.
What it does is narrower than many expect. Article 5 opens with the sentence that sets the tone: each country keeps the right to tax it has under its own law. The convention does not divide estates between the two countries; it removes the double charge afterwards, by credit.
| Article | Rule |
|---|---|
| Article 4 | domicile is decided by each country’s own law; where a person counts as domiciled in both, a tie-breaker decides: permanent home, centre of vital interests, habitual abode, nationality |
| Article 8(1) | property situated in one country: the other country gives a credit for the tax charged where the property is |
| Article 8(2) | property in a third country taxed by both: the country with the subsidiary taxing right gives the credit |
| Article 9 | a claim for credit or repayment within six years of the death or gift |
Source: GOV.UK, Inheritance Tax and “Rules on giving gifts”; HMRC Inheritance Tax Manual IHTM47020 and IHTM27212 (updated 7 April 2026); convention of 7 December 1977, SI 1978/1107, legislation.gov.uk; Revenue, double taxation relief for UK property. As of: read 6 November 2026.
Revenue describes the Irish end in practice: if you inherit UK property on which UK inheritance tax was paid, you can claim a credit against your CAT, based on the lower of the two effective rates, never more than the Irish tax, and only where the same property is taxed in both countries on the same event.
One reservation we state openly: the convention speaks of domicile, while since April 2025 the UK decides the reach of its inheritance tax by long-term residence. How the tie-breaker of Article 4 meets the new British test, we have found no published guidance on. For the effect on a typical estate the credit mechanism is what counts; for the question of which country has the subsidiary right over assets in third countries, it belongs checked in the individual case.
Britain: long-term residence and its tail
Britain does not let its long-standing residents go at once. Since 6 April 2025, HMRC’s manual says, a person who has been UK resident for at least 10 of the last 20 tax years is a long-term UK resident, and inheritance tax then reaches foreign assets as well. After you leave, the status stays with you: for at least 3 tax years after ten to thirteen years of residence, one more year for each further year, up to 10.
Foreign assets of someone who is not a long-term UK resident are excluded property. UK assets are a different matter: the house in Britain, the British bank account and British shares stay within UK inheritance tax whatever your residence. The tax itself, as GOV.UK sets out, is charged at 40 per cent on the estate above £325,000, a threshold that can rise to £500,000 when the home goes to children or grandchildren; gifts are free of tax if the giver lives for 7 more years.
Two clocks, one window
Alongside the British tail runs the Irish five-year rule. The two count from different events, and between them lies a window in which both countries can reach for worldwide assets: Britain through the tail, Ireland once the five years of residence are complete.
| Years after the move | United Kingdom | Ireland |
|---|---|---|
| 1 to 3 | long-term UK resident through the tail: worldwide assets | Irish assets only |
| 4 to 5 | still in the tail after more than thirteen years of UK residence, otherwise UK assets only | Irish assets only |
| from 6 | in the tail only after long UK residence, up to ten years; UK assets always | worldwide assets |
The British tail counts tax years after you cease to be UK resident and depends on how many of the last 20 years you were resident; the Irish clock counts five consecutive years of tax residence in Ireland. Where they do not fall together, they can overlap. Both clocks belong recalculated for the individual case.
Source: GOV.UK, Inheritance Tax and “Rules on giving gifts”; HMRC Inheritance Tax Manual IHTM47020 and IHTM27212 (updated 7 April 2026); convention of 7 December 1977, SI 1978/1107, legislation.gov.uk; Revenue, double taxation relief for UK property. As of: read 6 November 2026.
For a family that has lived in Britain for twenty years, the tail lasts ten tax years and therefore covers roughly the Irish years six to ten. Here the credit rules of the convention do the work, and here the order of gifts and the place of assets decide what each side actually charges.
The Irish rule that looks at the heir
An Irish feature that British families regularly overlook: Irish tax looks at the recipient as well. If a child who moved to Ireland with the family and became resident there inherits from a grandmother who never set foot in Ireland, Ireland can still reach for it. The British view of the estate of the person who dies is not enough here.
The convention eases the double charge on such an inheritance where its conditions are met, but it does not take Ireland out of the picture. Grandparents who stay in Britain belong in the family’s plan from the start.
What follows for a family
Three observations follow from setting the two systems side by side.
First: the Irish clock is long enough to plan on. Five full years are a span in which transfers of wealth can be put in order, if you start early.
Second: the British tail depends on your own history. A family that has lived in Britain for eleven years carries it for three tax years, one that has lived there for twenty carries it for ten. Working out where your family stands is the first calculation of any plan.
Third: the thresholds only look comparable. From parent to child, Ireland’s Group A at €420,000 stands against the British £325,000, but the two count differently. The British threshold applies to the estate of the person who dies, and gifts made more than 7 years before death drop out of the reckoning. The Irish thresholds apply to the person who receives and hold once in a lifetime; they do not renew with time. The British habit of giving early and waiting seven years therefore does not work the same way in Ireland.
This page does not replace estate planning. It is meant to stop anyone from asking the question only in year six. The formal start of the Irish years, registering with Revenue and the first return, lies in our tax registration as a non-dom.
More in Expert knowledge
The first step is a conversation
The five years run from the day you become resident. What is put in order in that time stays in order.