Capital Acquisitions Tax Consolidation Act 2003 section 67A

Payment of tax following determination of an appeal

Section 67A sets out the rules for payment of any additional capital acquisitions tax that becomes due following the determination of an appeal against a CAT assessment.

• Where an appeal against a CAT assessment is determined and the tax payable exceeds the amount already paid, the excess is due on the same date as the original assessment.
• However, if the taxpayer had already paid at least 90% of the tax ultimately found to be due before making the appeal, the balance is due within one month of the determination of the appeal.
• The section was introduced by Finance Act 2018 (section 51 and Schedule 1(c)).
• The practical effect is to incentivise substantial upfront payment of assessed tax before appealing, by offering a more favourable payment deadline for the balance.