In response to queries raised with Revenue regarding the operation of the CAT exemption (section 84) for gifts/inheritances taken exclusively for the purpose of discharging the “qualifying” expenses of an individual who is permanently incapacitated by reason of physical or mental infirmity, a new Part 22 has been added to the CAT Manual.

The new Part 22 sets out Revenue's interpretation of section 84 CATCA 2003 and notes that Revenue must be satisfied that the gift or inheritance has been, or will be, applied to such purpose and the expenses that qualify are those relating to medical care including the cost of maintenance in connection with such medical care. Also Revenue's position that the phrase “taken exclusively for the purpose of discharging qualifying expenses” is explained as referring to the intention in the mind of the disponer who provides the gift or inheritance.