As readers will be aware, Finance Act 2011 brought forward the Pay & File date for CAT from 31 October to 30 September. Therefore all gifts and inheritances with a valuation date in the 12 month period ending on the previous 31 August will be included in the return to be filed by 30 September.

For 2011, that means where the valuation date arises between 1 January and 31 August 2011, the Pay & File deadline is 30 September 2011. Readers should note that the period between the valuation date and the payment due date can be as short as one month i.e. if the valuation date occurs this month, payment of the relevant liability and the return is due by the end of next month. If the valuation date arises between 1 September 2011 and 31 December 2011, the Pay & File deadline will be 30 September 2012.

As a result of the change to the CAT pay and file deadline, Revenue are now issuing letters to those taxpayers who had already received correspondence indicating that the pay and file date was 31 October 2011 to advise them of the revised pay and file date of 30 September. This confusion is a byproduct of the rushed nature of Finance Act 2011, which at one stage contained a proposal to move all pay and file dates due on 30 September. The pay and file date for all taxes should be regularised at 31 October. The needless exception for CAT purposes is causing confusion for both Revenue and taxpayer alike.

Readers are also reminded that where the criteria for use of the “Short Form IT38” do not apply, e.g. where reliefs/exemptions/credits etc. are claimed, the Gift or Inheritance Tax return must be filed electronically through ROS. Also taxpayers identified as Phase 3A mandatory electronic filers must also pay and file their CAT liability on ROS.

Revenue's Information Leaflet IT39-Guide to completing the IT38 return (Pay and File) sets out further details of the CAT Pay & File deadline.