Capital Acquisitions Tax Consolidation Act 2003 Schedule 1

Valuation of limited interests

Schedule 1 sets out the rules and actuarial tables used to place a taxable value on limited interests β€” that is, interests in property that do not amount to full ownership, such as life interests or interests for a fixed period of time.

  • A life interest in a capital sum is valued by multiplying the sum by the age- and gender-appropriate factor from Table A; joint life and survivor interests are valued using the joint factors also found in Table A (Rules 1–5).
  • An interest for a fixed period (a "period certain") is valued by multiplying the capital sum by the appropriate factor from Table B, with a day-count apportionment where the period is not a whole number of years (Rule 6).
  • Where a life interest is guaranteed for a minimum fixed period, the taxable value is the higher of the life-interest value and the fixed-period value (Rule 7).
  • Any limited interest that cannot be valued under Rules 1–7 is treated as a series of separate absolute interests, each payment being taxed as a standalone gift or inheritance (Rule 8).

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