I assume the principal private residences you are referring to is that of the disponer however it is important to note that Capital Acquisitions Tax (CAT) is a beneficiary-based tax on gifts and inheritances. For CAT purposes, the relationship between the person giving a gift or inheritance (i.e. the disponer) and the person who receives it (i.e. the beneficiary) determines the maximum amount, known as the “Group threshold”, below which CAT does not arise.
In cases where the inheritance relates to a property the beneficiary resides in, the Dwelling House exemption may apply.
To qualify for the exemption, the inherited property must have been the disponer’s principal private residence at the date of death. This requirement is relaxed in situations where the deceased person left the property before the date of death due to ill health; for example, to live in a nursing home. The beneficiary must also have lived in the house for 3 years prior to the date of the inheritance and must continue to live in the house for 6 years after that date.
In addition, the beneficiary must not have a beneficial interest in any other residential property. Detailed guidance on the dwelling house exemption has been published on the Revenue website at www.revenue.ie/en/tax-professionals/tdm/capital-acquisitions-tax/cat-part24.pdf.
I am advised by Revenue that the principal private residences are not separately identifiable on the Capital Acquisitions Tax return form. Therefore, it would not be possible to conduct an assessment of the fiscal and distributional impact of introducing an exemption of this nature.