No capital gains tax arises on death but the fund will be liable to an exit tax at 23%, inheritance tax/CAT may apply on the grossed up fund, this will be payable by the beneficiary of the shares. cat would be payable regardless of how the are held. there is a threshold depending on your relation to the disponer as you mentioned
In relation to the benefits of holding share in a unit linked fund there is an offset available. the exit tax that has been deducted from the policy can be offset against the cat liability arising as a result of the inheritance of this policy
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