Capital Acquisitions Tax Consolidation Act 2003 section 24

Values agreed

Section 24 provides that, for the purposes of the annual 1% discretionary trust tax charge, the market value of real property or unquoted shares agreed between the accountable person and Revenue for one chargeable date may also be used for the next two chargeable dates, subject to certain conditions and exceptions.

• Where a 1% discretionary trust tax charge arises and Revenue has agreed the market value of real property or unquoted shares following a written application, that agreed value may stand for the next two chargeable dates provided the same property remains subject to the charge on each date.
• The agreed value ceases to be binding if material facts were not disclosed, if there is a change in tenure of real property or a change in ownership, capital structure, or shareholder rights in the case of unquoted shares before the third chargeable date.
• The accountable person may request a revaluation before the third chargeable date if there has been a change affecting the market value of the real property or the unquoted shares beyond what would normally be expected.
• An agreed valuation under this section is binding only on the persons who are accountable for payment of the discretionary trust tax on the first, second, and third chargeable dates.