How to Appeal a CAT (Capital Acquisitions Tax) Assessment in Ireland

If Revenue has raised a Capital Acquisitions Tax assessment on a gift or inheritance that you believe is wrong — a disputed asset valuation, a refused relief, or the wrong group threshold applied — you have the right to appeal it to the Tax Appeals Commission, the independent statutory body that decides Irish tax disputes separately from Revenue.

CAT assessments are appealed under the same legal mechanism as any other tax head, following Part 40A of the Taxes Consolidation Act 1997.

What CAT Decisions Can You Appeal?

• A disputed asset valuation — Revenue disagrees with the market value used for the gifted or inherited property, shares or other assets on the valuation date
• A refused relief — Agricultural Relief, Business Relief, or the Dwelling House Exemption declined or reduced
• The wrong group threshold applied — a dispute over whether the beneficiary falls under Group A (parent to child), Group B (other close relatives) or Group C (all others), which sets the tax-free threshold
• Aggregation of prior gifts or inheritances — disagreement over which earlier benefits from the same group threshold should count toward the current one
• A surcharge or penalty for a late or incorrect IT38 return

Who Can Appeal a CAT Assessment?

The beneficiary who received the gift or inheritance — or their solicitor or agent acting on their behalf — can appeal a CAT assessment or determination. You do not need a solicitor or tax adviser to lodge the appeal yourself, though valuation disputes on property or business assets are often strengthened by an independent professional valuation.

What Must Your Notice of Appeal Include?

A valid notice of appeal under section 949I should include:

1. Your name and address as the beneficiary
2. The Revenue assessment or IT38 reference number
3. The valuation date and the gift or inheritance in question
4. The amount assessed or disputed
5. Your grounds of appeal — set out clearly, one point per paragraph
6. A statement that the appeal is within the 30-day time limit
7. A request that the assessment be reduced, discharged or varied

For valuation disputes, cite specific comparable evidence — a professional valuation, comparable sale or share prices as at the valuation date — rather than a general assertion that the figure is too high.

How to Lodge Your Appeal

Online

Submit through the Tax Appeals Commission's portal at taxappeals.ie, uploading your notice of appeal as a PDF.

By Post

Tax Appeals Commission
Fitzwilliam Court
Leeson Close
Dublin 2
D02 YW24

Use recorded delivery if posting, so you have proof of submission within the 30-day window.

What Happens After You Lodge Your CAT Appeal?

Revenue is notified once your appeal is registered. Valuation disputes are frequently resolved once you submit supporting professional evidence, without needing a formal hearing before a Commissioner. Relief and threshold disputes more often proceed to a written or oral hearing where the facts are contested.

Frequently Asked Questions

Do I need to pay the disputed CAT before appealing?

No. Lodging a notice of appeal does not require you to pay the disputed amount first, though interest may continue to accrue on any CAT ultimately found to be due — check your specific liability position if unsure.

Can I appeal a refused Agricultural or Business Relief separately from the valuation?

Yes. A relief refusal can be appealed on its own grounds — for example, that the active-farmer or qualifying-trade conditions were in fact met — even where the underlying asset valuation itself isn't in dispute.

What if my dispute is about which group threshold applies to me?

State clearly in your notice of appeal why you believe the relationship to the disponer places you in a different group (A, B or C) than Revenue has assessed, since this directly changes your tax-free threshold and the tax due.