Aggregation rules for calculation of Capital Acquisitions Tax
(The aggregation rules applicable to a particular inheritance or gift are those which applied at the date of death or the date of gift. The Valuation Date is not relevant to aggregation rules.)
Benefits taken on or after 5th December 2001:
All benefits taken from the same Group Threshold since 5th December 1991 are added together to calculate the tax on the latest benefit.
Calculation in respect of the latest of a series of benefits taken since 1991:
- Aggregate all prior benefits within the same group threshold as the current benefit with the current benefit and calculate the tax on the total.
- Aggregate all prior benefits within the same group threshold as the current benefits, excluding the current benefit and calculate the tax on the total.
- Subtract tax at (2) from tax a (1) - this gives tax referable to the current benefit.
This calculation applies where aggregation applies in relation to same group/class threshold only.
Benefits taken between 1st December 1999 and 4th December 2001 inclusive:
All benefits taken from the same Group Threshold since 2nd December 1988 are added together to calculate the tax on the latest benefit.
Benefits taken between 2nd December 1998 and 30th November 1999 inclusive:
All benefits taken from any source (i.e. all class Thresholds) since 2nd December 1988 are added together to calculate the tax on the latest benefit.
Definition of revised class threshold to be used to determined class threshold where aggregation of all benefits taken from any source applies:
'revised class threshold', in relation to a taxable gift or a taxable inheritance included in any aggregate of taxable values under the provisions of paragraph 3, means-
- the class threshold that applies to that taxable gift or taxable inheritance, or
- the total of the taxable values of all the taxable gifts and taxable inheritances to which that class threshold applies and which are included in that aggregate,
whichever is the lesser:
Provided that where the revised class threshold so ascertained is less than the smallest of the class thresholds that apply in relation to all of the taxable gifts and taxable inheritances included in that aggregate, the revised class threshold shall be that smallest class threshold;
Benefits taken on or after 26th March 1984 and prior to 2nd December 1998:
All Benefits taken by the beneficiary since 2 June 1982 from any source (i.e. all Class Thresholds) are added together to calculate the tax on the latest benefit.
Benefits taken after 2nd June 1982 and before 26th March 1984:
All benefits taken by the beneficiary on or after 2nd June, 1982 from the same group threshold are aggregated to calculate the tax on the later benefit.
Benefits taken prior to 2nd June 1982:
All benefits taken after 28th February 1974 and prior to 2nd June 1982 by a beneficiary are aggregated with any benefit taken since 28th February 1969 where the benefit is from the same disponer.