CAT Pay-and-File: Why a 1 September Inheritance Isn't Due Until the Following 31 October
Capital Acquisitions Tax (CAT) runs on a single annual deadline — 31 October — but which 31 October depends entirely on your valuation date. If that date falls between 1 January and 31 August, you pay and file by 31 October of the same year. If it falls between 1 September and 31 December, you don't pay and file until 31 October of the following year. So a gift or inheritance valued on 15 September 2025 isn't due until 31 October 2026 — a full 13 months later.
This single rule trips up more people than almost any other part of the CAT system. Families assume the clock starts when the person died, or when probate issued, or when the cheque cleared — and then either panic that they're "late" when they have months to spare, or miss the real deadline because they counted from the wrong event. This guide walks through exactly how the deadline is set, with a full worked timeline, and shows what late interest and the late-filing surcharge actually cost. All figures are checked against Revenue's official CAT pages.
The two-deadline rule in one table
Revenue splits the calendar year into two halves. The split point is the valuation date — not the date of death, not the grant of probate, and not the day the money landed in your account. Here is the exact mapping Revenue publishes:
| If your valuation date falls… | Pay-and-file deadline | How much lead time |
|---|---|---|
| 1 January – 31 August | 31 October of the same year | 2 to 10 months |
| 1 September – 31 December | 31 October of the following year | 10 to 13 months |
So the people with the least time are those whose valuation date lands in late August — they may have barely two months. The people with the most time are those whose valuation date is in early September, who get over a year. That asymmetry is the whole story, and it is confirmed on Revenue's Important dates for CAT page and the How and when do you pay and file? page.
Conor's inheritance, valuation date 15 September 2025. Conor's aunt died on 4 March 2025. After dealing with the funeral, gathering account statements and getting the house valued, the personal representative (Conor's cousin, acting as executor) was able to establish the valuation date as 15 September 2025 — the date the estate's assets could be retained for the benefit of the beneficiaries.
Conor inherits €120,000 in cash plus a half-share of his aunt's home worth €230,000, so his benefit is €350,000. He is a nephew, so he falls into Group B.
- Step 1 — find the deadline. Valuation date 15 September 2025 is inside the 1 September – 31 December band, so the pay-and-file deadline is 31 October of the following year: 31 October 2026. The 4 March date of death is irrelevant to the deadline.
- Step 2 — apply the threshold. The Group B tax-free threshold is €40,000 (for benefits taken on or after 2 October 2024). Assuming Conor has had no prior Group B gifts or inheritances since 5 December 1991, his taxable amount is €350,000 − €40,000 = €310,000.
- Step 3 — apply the rate. CAT is charged at 33%. So €310,000 × 33% = €102,300 of CAT.
- Step 4 — the deadline check. Conor must file an IT38 return and pay €102,300 by 31 October 2026. He has from September 2025 until then — about 13 months — to arrange funds (for example, by realising part of the cash before the property sale completes).
Figures: 33% rate, €40,000 Group B threshold and the valuation-date deadline rule are all from Revenue. The personal numbers are illustrative.
What "valuation date" actually means — and why it differs for gifts vs inheritances
The valuation date is the date on which the market value of the property is established for CAT purposes. It is the pivot the whole deadline turns on, and it is set differently depending on whether you received a gift or an inheritance.
For a gift
The valuation date for a gift is almost always straightforward: it is the date of the gift itself — the day you became beneficially entitled in possession to the property. If your parent transfers €30,000 to you on 12 June, the valuation date is 12 June, and the deadline is 31 October of that same year.
For an inheritance
For an inheritance, the valuation date is usually not the date of death. It is generally the earliest of:
- the date the property can be retained for the benefit of the beneficiary;
- the date it is actually retained for that benefit; or
- the date it is transferred or paid over to the beneficiary.
In practice, for a straightforward estate this is often around the date the grant of probate or administration issues, because that is the point at which the personal representative can lawfully gather in the assets and apply them for the beneficiaries. That is why an estate where someone died in March can have a valuation date in September — the date of death and the valuation date can be many months apart. Revenue sets this out in its CAT Manual on the valuation date.
Same death, two different deadlines. Two siblings, Aoife and Daire, each inherit from a parent who died on 20 July 2025.
- Aoife's share is a deposit account that the executor is able to release to her on 14 August 2025. That valuation date is in the 1 January – 31 August band, so Aoife's deadline is 31 October 2025 — only about 11 weeks away.
- Daire's share depends on the family home, which can't be valued and retained for his benefit until probate issues on 2 September 2025. That valuation date is in the 1 September – 31 December band, so Daire's deadline is 31 October 2026.
Same parent, same date of death, three weeks apart in valuation date — and a full year apart in deadline. This is exactly why you must work out the valuation date for your benefit, not for "the estate."
Interest and the late-filing surcharge — and how they compound
If you miss the 31 October deadline, two separate charges can apply, and it's important not to confuse them.
The late-filing surcharge (on the tax)
The surcharge is a one-off percentage added to your CAT bill for filing the IT38 late:
| How late the return is filed | Surcharge | Capped at |
|---|---|---|
| Less than 2 months late | 5% of the tax | €12,695 |
| 2 months or more late | 10% of the tax | €63,485 |
These percentages and caps are from Revenue's What charges are there for late filing? page.
Daily interest (on the unpaid tax)
On top of the surcharge, interest runs on any CAT paid late. Revenue charges interest at 0.0219% per day on the overdue amount (a reduced rate of 0.0164% per day applies where qualifying property is being paid in instalments). Interest accrues every single day from the due date until you pay, so the longer the delay, the more it builds.
How the two charges stack — Niamh's client, €30,000 of CAT due 31 October 2025. Suppose a beneficiary owes €30,000 of CAT and files and pays on 15 January 2026 — that is 76 days late, so more than two months.
- Surcharge: filing 2+ months late triggers the 10% surcharge → €30,000 × 10% = €3,000 (well under the €63,485 cap).
- Interest: 76 days × 0.0219% per day = 1.6644% → €30,000 × 1.6644% ≈ €499.
- Total cost of being late: roughly €3,000 + €499 = €3,499 on top of the original €30,000.
The lesson: the surcharge is a cliff edge — crossing the two-month mark jumps it from 5% to 10% — while interest is a slow bleed that never stops until you pay. Filing on time is by far the cheapest option. Interest figure rounded; calculated using Revenue's published daily rate.
Paying CAT online through ROS or myAccount
You file the IT38 and pay the CAT through one of three channels, set out on Revenue's How to pay your CAT page:
- ROS (Revenue Online Service) — for registered customers and agents. You can pay by ROS Debit Instruction (RDI), a Single Debit Instruction (SDI), or debit/credit card.
- myAccount — for individuals who are not ROS-registered. You can pay by Single Debit Instruction or debit/credit card.
- Paper IT38S — a simplified paper return for the most straightforward cases, posted to Revenue with a cheque before the deadline.
The ROS pay-and-file extension nuance
Revenue runs an extended pay-and-file deadline for customers who both file the return AND pay the tax online through ROS. This pushes the effective deadline a couple of weeks past 31 October (typically into mid-November), and the exact date is announced by Revenue each year. Two things are essential to understand:
- It is all-or-nothing. You must both file and pay online to qualify for the extension. Filing online but paying by cheque does not get the extension — Revenue is explicit that "the extended pay and file deadline does not apply to payments made by cheque," and cheque payments with the IT38 must reach Revenue before the standard 31 October due date.
- Don't bank on it. Because the extended date is set annually and can change, treat 31 October as your real deadline and the ROS extension as a small safety margin — not a planned buffer. Check the current year's date on Revenue's site before you rely on it.
- The CAT deadline is always a 31 October — but which one depends on the valuation date, not the date of death.
- Valuation date 1 Jan – 31 Aug → due 31 October the same year. Valuation date 1 Sep – 31 Dec → due 31 October the following year.
- A 15 September 2025 inheritance has a deadline of 31 October 2026 — about 13 months of lead time.
- For a gift, the valuation date is usually the date of the gift. For an inheritance, it's usually around the grant of probate, not the date of death.
- File late and you face a 5% surcharge (under 2 months, cap €12,695) or 10% (2+ months, cap €63,485), plus interest at 0.0219% per day on unpaid tax — the two charges stack.
- Filing AND paying online via ROS earns a short extension (usually into mid-November), but it never applies to cheque payments. Treat 31 October as the real deadline.
Frequently asked questions
Does the CAT deadline run from the date my relative died?
No. The deadline runs from the valuation date, which for an inheritance is usually around the date probate or administration issues — not the date of death. Someone who died in March can easily have a valuation date in September, pushing the deadline to 31 October of the following year.
My valuation date is 1 September 2025. When exactly is my CAT due?
1 September falls inside the 1 September – 31 December band, so your pay-and-file deadline is 31 October of the following year — 31 October 2026. A valuation date of 31 August 2025, by contrast, would have been due 31 October 2025. One day either side of the 1 September line moves the deadline by a full year.
Do I have to file an IT38 even if no tax is payable?
You must file an IT38 once the total taxable value of benefits you have received in a group reaches 80% of the relevant group threshold, even if the threshold itself isn't exceeded and no tax is due. If you're below 80%, no return is generally required. Always check Revenue's current IT38 guidance for your situation.
What does filing late actually cost?
A late return attracts a surcharge of 5% of the tax (capped at €12,695) if filed less than two months late, rising to 10% (capped at €63,485) if filed two months or more late. Separately, interest of 0.0219% per day runs on any tax paid after the deadline. The two charges are cumulative.
Is there really a November extension, or do I have to pay by 31 October?
There is a short extension — but only if you both file and pay online through ROS. It typically pushes the deadline into mid-November, and Revenue sets the exact date each year. It never applies to cheque payments. Plan around 31 October and treat the ROS extension as a buffer, not a target.
Can I pay the CAT in instalments?
In limited cases — mainly where the benefit includes agricultural or relevant business property — CAT can be paid by instalments, and a reduced interest rate of 0.0164% per day applies while instalments are kept up. If an instalment falls overdue, the standard rate resumes. Check eligibility and conditions with Revenue or a qualified adviser before relying on instalments.
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