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Inheritance Tax Compared

Inheritance Tax: UK vs Ireland, Compared for 2026

The UK and Ireland tax inheritances in almost opposite ways. Here is who pays, how much, and what happens when an estate crosses the border.

7 min read · Written by the Fairchild Oldfield team · Last reviewed: August 2026

33% v 40%
Ireland charges 33% Capital Acquisitions Tax on the person who inherits. The UK charges 40% on the estate at death. The rate is only half the story: the two taxes fall on different people at different moments.
Source: Revenue.ie and gov.uk, as at August 2026, subject to change.
Inheritance tax in the UK and Ireland differs mainly in who pays and when. The UK charges 40% on the value of the estate at death, above a £325,000 nil-rate band. Ireland charges 33% Capital Acquisitions Tax on each beneficiary, above lifetime group thresholds that start at €400,000 for a child. A longstanding UK-Ireland convention stops the same asset being taxed twice.

Most comparisons online still quote superseded UK figures, and few explain the structural gap: UK inheritance tax is a one-off charge on the estate, while Irish CAT is a running total kept against each beneficiary across their lifetime. That difference, not the headline rate, decides who ends up with a bill. This guide is general information for England and Wales, not advice.

What is the difference between inheritance tax in the UK and Ireland?

The UK taxes the estate; Ireland taxes the beneficiary. UK inheritance tax (IHT) is 40% on the estate above the nil-rate band, settled by the executors before assets pass down. Irish Capital Acquisitions Tax (CAT) is 33%, paid by each person who inherits, above a lifetime threshold set by their relationship to the deceased.
FeatureUnited Kingdom (IHT)Ireland (CAT)
Who paysThe estate, via executorsThe beneficiary who inherits
Headline rate40% (36% if 10%+ to charity)33%
Tax-free allowance£325,000 nil-rate band, plus up to £175,000 residence bandGroup A €400,000, Group B €40,000, Group C €20,000 (lifetime)
How the allowance worksPer estate, at deathPer beneficiary, cumulative over a lifetime
Valuation pointDate of deathThe valuation date, often the grant of representation
Spouse or civil partnerExemptExempt
Lifetime giftsFree after 7 years (taper applies)Counted against the lifetime threshold, no 7-year escape

Source: gov.uk, Inheritance Tax and Revenue.ie, CAT thresholds, as at August 2026, subject to change.

Who pays the tax, the estate or the person who inherits?

In the UK the estate pays, so beneficiaries usually receive their share after tax is settled. In Ireland the beneficiary pays, so two people inheriting equal amounts from the same estate can owe very different sums depending on their relationship to the deceased and what they have already received in their lifetime.

This is the change most people miss. UK inheritance tax is worked out once, on the whole estate, and the executors handle it (how UK inheritance tax works). Where an estate is under the threshold, no one pays anything.

Irish CAT is personal to each beneficiary. A child inheriting €500,000 uses the €400,000 Group A threshold; a niece inheriting the same amount only has the €40,000 Group B threshold, so she pays far more on an identical inheritance. Each beneficiary files and settles their own bill.

Source: Revenue.ie, IT38 returns, as at August 2026, subject to change.

How do the thresholds and rates compare?

The UK gives a £325,000 nil-rate band per person, plus up to £175,000 when a home passes to children, so a couple can pass up to £1m before 40% applies. Ireland gives each beneficiary a lifetime threshold based on relationship, from €400,000 for a child down to €20,000 for a stranger, with 33% on the excess.

UK bands are frozen until 5 April 2031, extended at the 2025 Budget on 26 November 2025. The residence nil-rate band is withdrawn by £1 for every £2 an estate exceeds £2,000,000, so it tapers away on larger estates. Farm and business assets keep 100% relief on the first £2,500,000 combined per person from 6 April 2026, transferable to £5,000,000 per couple, and 50% above (the 2025 Budget changes in full).

AllowanceUKIreland
Standard band£325,000 nil-rate band€400,000 to a child (Group A)
Home to childrenUp to £175,000 residence bandDwelling house exemption, on strict conditions
Sibling, niece, nephewSame £325,000 band€40,000 (Group B)
Everyone elseSame £325,000 band€20,000 (Group C)
Rate above the allowance40%33%

Source: gov.uk, Inheritance Tax and Revenue.ie, CAT groups, as at August 2026, subject to change. A £325,000 band is roughly €375,000 depending on the exchange rate.

Worked example: how the same estate is taxed in each country

Take a parent leaving a £600,000 estate, including the family home, to one adult child. In the UK the estate pays about £40,000. In Ireland, on a similar sum of roughly €700,000, the child pays about €99,000. Same family, very different outcome, because the allowances and the taxpayer differ.

The figures below assume the child did not live in the home, so the UK residence band applies but the Irish dwelling house exemption does not. They ignore exchange-rate movement and any earlier gifts. They are an illustration, not a calculation for a real estate.

StepUnited KingdomIreland
Estate or inheritance£600,000€700,000
Allowance£325,000 + £175,000 = £500,000€400,000 (Group A)
Taxable amount£100,000€300,000
Rate40%33%
Tax due£40,000€99,000
Who settles itThe estateThe child

The Irish bill is larger here because a single child gets one €400,000 threshold, while the UK stacks a £325,000 band on top of a £175,000 home allowance. Reverse the relationship, say a childless person leaving £600,000 to a nephew, and the gap widens further: the UK still allows £325,000, but Ireland allows only €40,000, so almost the whole inheritance is taxed at 33%.

Source: rates and bands from gov.uk and Revenue.ie, as at August 2026, subject to change.

How do gifts and the 7-year rule differ?

The UK lets most lifetime gifts fall out of inheritance tax entirely if the giver survives seven years, with taper on the tax between years three and seven. Ireland has no seven-year escape: gifts count towards the same lifetime group threshold as inheritances, so a gift today reduces the tax-free room left when the person later dies.

The UK also gives an annual £3,000 gift exemption, £250 small gifts to any number of people, and normal exemptions for wedding gifts and gifts from surplus income. Give more than that and survive seven years, and the gift usually drops out of the estate.

Ireland aggregates. Gifts and inheritances a person receives within the same group since December 1991 are added together against their threshold, so there is no clean reset. Ireland does allow a €3,000 small gift exemption per giver each year, which sits outside the running total (how gift exemptions work in the UK).

Source: gov.uk, gifts and Inheritance Tax and Revenue.ie, small gift exemption, as at August 2026, subject to change.

What happens if you inherit across the UK-Ireland border?

Where the same asset would be taxed by both UK IHT and Irish CAT, a UK-Ireland double taxation convention gives credit relief so it is not taxed twice in full. Ireland credits the UK tax paid on UK property, capped at the Irish tax on the same asset. Which country taxes what depends on where the asset sits and on domicile, which can be complex.
  1. Identify where each asset is located. UK property is generally within the scope of UK inheritance tax; Irish-situated assets fall within Irish CAT.
  2. Check domicile and residence. A person UK-domiciled is usually within UK IHT on worldwide assets, while Irish CAT can apply where the giver or receiver is Irish-resident, so both taxes can be triggered by one estate.
  3. Apply the convention. Where both taxes hit the same asset, credit relief under the UK-Ireland convention reduces the double charge, giving credit for the tax already paid on that asset.
  4. Take cross-border advice. Situs, domicile and the interaction of two tax systems are technical, so most people in this position use a solicitor or tax adviser qualified in both countries.

If your estate touches both countries, it is worth folding the comparison into your wider estate planning early, rather than leaving executors to reconcile two tax systems later.

Source: Revenue.ie, double taxation relief (UK), as at August 2026, subject to change.

Frequently asked questions

Common questions compare the two headline rates, ask who is taxed on a cross-border inheritance, and check the tax-free threshold for a child in Ireland. The answers below are based on gov.uk and Revenue.ie guidance, current as at August 2026 and subject to change.

Is inheritance tax higher in Ireland or the UK?

The UK headline rate of 40% is higher than Ireland's 33%, but the tax that falls on a family depends on the allowances and who pays. A UK couple can pass up to £1m where a home goes to children, while an Irish child gets a €400,000 lifetime threshold and pays personally, so a modest estate can create a larger bill in Ireland for a distant relative than in the UK.

Do I pay UK inheritance tax on money inherited from Ireland?

UK inheritance tax is charged on the estate, not usually on the person receiving a gift, so a UK resident inheriting from an Irish estate does not normally pay UK inheritance tax on the money received. Irish CAT may apply instead, and other UK taxes such as income tax on what you do with the money afterwards can arise. Cross-border cases turn on domicile and where assets sit, so advice is sensible.

How much can a child inherit tax free in Ireland?

A child can inherit up to €400,000 tax free from a parent under the Group A threshold, as at August 2026. This is a lifetime figure covering gifts and inheritances from parents since December 1991, not a fresh allowance for each inheritance. Anything above it is taxed at 33% (Revenue.ie, subject to change).

Is there a double taxation agreement between the UK and Ireland?

Yes. A UK-Ireland convention covers UK inheritance tax and Irish Capital Acquisitions Tax, so the same asset is not taxed twice in full. Ireland gives credit for UK tax paid on UK property, limited to the Irish tax on that asset. It applies only where identical property is taxed in both countries on the same event.

About Fairchild Oldfield

The Fairchild Oldfield team brings together estate planning, tax awareness and client care, working discreetly with families across England and Wales.

Fairchild Oldfield are estate planning specialists and will writers, not a firm of solicitors. This article is general information based on practical experience, not legal, tax or financial advice.

Important: This article is general information only and is not legal, tax or financial advice. Reading it does not create a professional relationship. It describes the position for England and Wales, and Irish figures are included for comparison only; other jurisdictions and cross-border cases differ. Figures and rules are current as at August 2026 and are subject to change, and exchange rates move. Before acting, many people choose to seek advice from a suitably qualified professional, such as a solicitor, a STEP practitioner, an accountant, or an FCA-authorised financial adviser, who can consider their individual circumstances, including advice qualified in both countries where an estate crosses the border.

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