The beneficiary is UK resident and domiciled
BM: Yes
The deceased is Irish resident and domiciled
BM: Yes
It is the domicile of the deceased person that dictates the exposure to UK Inheritance Tax, the domicile/residence of the beneficiary is not relevant for UK Inh Tax purposes.
BM: OK, accepted.
Therefore it seems that UK Inheritance Tax would only apply if the deceased person had property situated in the UK, in excess of the current UK Inh Tax threshold of £325,000.
BM: Seems to contradict the above statement in that the deceased person was domiciled outside the UK so no UK inheritance tax would be payable regardless of the location of an asset of the estate (none in the UK anyway).
So IMV the beneficiary may only have to pay Irish C.A.T. if the benefit taken from his/her parent exceeds the current Group A threshold, taking into account any other benefits taken from Group A before this one, and all the property in the parent's estate is situated in Ireland, or the property in the UK is less than the above threshold.
BM: But the beneficiary is not domiciled/resident in Ireland and surely therefore not liable to CAT?