Revenue eBrief No. 246/24

24 September 2024

Capital Acquisitions Tax Manual Part 11 - Agricultural Relief

Section 89 of the Capital Acquisitions Tax Consolidation Act 2003 provides for a relief from Capital Acquisitions Tax in respect of gifts and inheritances of agricultural property. CAT Manual Part 11 - Agricultural Relief, which provides an overview of the relief, has been revised and refreshed throughout to provide clearer and more comprehensive guidance. The main changes are set out below.

• Finance (No.2) Act 2023 amendments are reflected throughout the manual, with new examples included where appropriate.
• The concessional treatment which allowed the active farming requirements to commence from the date of inheritance (formerly para. 11.6.3.1 ) has been withdrawn. It is not consistent with certain changes made by Finance (No.2) Act 2023 which provide for the clawback period to commence on the valuation date in all cases.
• Appendix 1: CAT Agricultural Relief – Q&As has been removed. The contents have been substantially incorporated into the body of the manual with the following material exceptions:
  • Q.11 on the period of time afforded to a beneficiary to find a new active farmer tenant where a lease ceases has been removed as the treatment is not consistent with the legislation.
  • Q.18 on the application of the clawback formula in subsection (4)(aa) has been clarified as the previous material was inaccurate.