How a double taxation treaty protected an inheritance
Radu moved from Romania to Limerick five years ago for work. He'd built a life here — a job he loved, friends, and a sense of home. When his uncle passed away and left him an apartment in Dublin, it felt like a gift that would keep him rooted in Ireland. But then reality hit. Radu wasn't sure what taxes he'd owe, and he worried he might have to pay tax twice — once in Ireland and again in Romania. The thought made his head spin.
He reached out to a solicitor to understand where he stood. The solicitor quickly explained that as a non-Irish national inheriting Irish property, Radu would be liable for Capital Acquisitions Tax (CAT) in Ireland. But the solicitor also brought good news: Ireland and Romania have a double taxation treaty. This treaty exists precisely to stop people in Radu's situation from being taxed unfairly twice on the same inheritance.
Once the solicitor confirmed the treaty applied to his circumstances, a tax credit system kicked in. Any tax Radu paid in Romania on the inheritance would be credited against what he owed in Ireland. This meant he wouldn't be paying twice — the two countries would coordinate their tax claims. The relief was enormous. Radu could accept his uncle's gift without the shadow of double taxation looming over him.
Non-Irish nationals inheriting Irish property are subject to Capital Acquisitions Tax (CAT) in Ireland. However, Ireland has double taxation treaties with many countries, including Romania. These treaties prevent the same inheritance from being taxed twice. When both countries have a tax claim on an inheritance, the treaty allows you to claim a credit in one country for taxes already paid in the other. You'll generally pay tax in the country where the property is located, then offset any tax owed elsewhere using the treaty credit mechanism. Always check whether Ireland has a treaty with your home country, as this dramatically affects your tax liability.
CAT must be paid within four years of the date of inheritance. If you inherit property on 1 March, your deadline is 1 March four years later. Missing this deadline can result in interest and penalties, even if you're waiting to claim a treaty credit. Additionally, tax returns must be filed within two years to avoid automatic penalties. If you're a non-Irish national inheriting Irish property, start the process early — coordinate with your home country's tax authorities if needed, and get professional advice before deadlines approach. Delays in confirming treaty status do not extend your payment deadline.
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