Finance (No. 2) Bill 2023 - Capital Acquisitions Tax (“CAT”)

Mandatory Reporting of interest-free loans

The Bill introduces a new CAT reporting requirement in respect of interest-free “specified loans” meeting the following conditions:

  • A benefit arises in respect of the loan under CAT principles
  • A loan advanced from a “close relative” or certain companies owned by close relatives
  • No interest has been paid on the loan within 6 months of the calendar year end and
  • The balance on the loan (aggregated with any other specified loan in the relevant period) exceeds €335,000 for at least one day in the calendar period.

Close relative, for the purposes of this section includes a parent, civil partner of a parent, lineal ancestor or descendant, sibling and aunt or uncles.

The new measure comes into effect from 1 January 2024.

Clawback of Agricultural Relief and Business Relief

The Bill contains a number of technical amendments to the clawback provisions of CAT Agricultural Relief and Business Property relief.

Return to Finance (No.2) Bill 2023 Commentary

Team Members

Jackie Masterson

Head of Tax, Tax Partner

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