Brendan Burgess
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If the grandparents kept the 40k and invested it properly themselves all things being equal it would double every 10 years (rule of 72) so now they have €160k in their estate and, as you say they can pass on €40k tax free to tiny Tim but the excess would be taxed at 33% an extra €39k in CAT payable compared to making the gift earlier.
@Marc
You are making an 18 year plan which might well work out. But a lot could go wrong as well.
Especially if the 18 year old gets their hands on €1m.
Or maybe the Family Partnership can stop him getting his hands on the €1m until it's ready to hand it over? I can see all sorts of family disputes arising with 5 people involved now.
If the grandparents leave the money after them, the capital gains will disappear which will offset some of the extra CAT payable.
I would really need to see a case study with reasonable assumptions and full ongoing tax and professional expenses factored into it.
As Tommy said:
I'm definitely not getting into the weeds on this one except to note that throughout my career whenever I have seen people build longterm plans on the back of complex and/or expensive contracts, agreements or structures, more often than not these go awry because circumstances change, priorities change and/or the people running them neglect them.