Technical article

Ireland and the Netherlands: Two Countries That Reach the Settlor's Residence

For Ireland, a settlor who is still resident, or an heir who is, brings the tax in.

By Neil Solomon · 4 min read

Picture a couple born in the United States who have lived most of their lives in Ireland, and who set up a trust for their daughter in the Netherlands. Years later, one of them moves back to the US. The daughter asks: does the tax office in her country care where my parents lived?

In these two countries the sources say yes, and in different ways.

Ireland. Capital Acquisitions Tax is the Irish tax on gifts and inheritances. It is 33% and it falls on the person who receives, above a tax-free threshold. PwC, tier B, says it applies if either the giver or the receiver is resident or ordinarily resident in Ireland, whatever their domicile. It always applies to assets that sit in Ireland. The tax is paid by the receiver, who files the return. A spouse is exempt.

The thresholds are lifetime and add up from 5 December 1991, and the sources differ on the numbers. A law firm's page from March 2023 (tier C) gives EUR 335,000 for a child, EUR 32,500 for a brother or sister, and EUR 16,250 for others. A 2026 site (tier U) gives EUR 400,000, EUR 40,000 and EUR 20,000 since 2 October 2024. The second page is the later one, and it is not an official page, so a family may want the revenue office's own table.

Two more Irish points. A person not domiciled in Ireland is not treated as resident for this tax until five consecutive years of residence. And Ireland's residence test is 183 days in a year, or 280 days over two years with at least 30 in each. On the income side, Matheson (tier B) says a resident beneficiary of an offshore trust may face income tax even on a capital payment, and cites effective rates of 55% or 67% in some cases where Irish tax and Irish domicile both play a part. A person who is resident but not domiciled pays on foreign income only when it is brought in.

The Netherlands. Gift and inheritance tax runs from 10% to 40%, depending on the relationship, and falls on the heir. PwC says it applies to gifts and inheritances from Dutch residents. Dutch nationals stay in reach for 10 years after leaving the country for inheritance, and anyone stays in reach for one year after leaving for gifts. Chambers 2026 (tier B) says gift tax on trust distributions, and inheritance tax, apply only if the settlor is, or is treated as, a Dutch resident. Trust assets are treated as separate private assets, taxed to the settlor or the heirs, and a beneficiary with a fixed interest is taxed in Box 3. Box 3 is the Dutch tax on savings and investments, a flat 36% on a deemed return, with an exemption of EUR 59,357 a person.

The Dutch figure in the last row comes from a secondary website (tier U) that looks out of date. The rates in PwC's page are the firmer ones.

You might say: "My parents have left, so that ends it." For the Netherlands, the sources point to a window: 10 years for Dutch nationals on inheritance and one year on gifts. For Ireland, a settlor who is still resident, or an heir who is, brings the tax in. A move away may close one door and leave another open.

You could write down, for the settlor and each heir, the country and the year of each move. You could also ask the trustee which of the two countries has the trust on its records.

The family reach is clear. A grandchild moving to Dublin or Utrecht becomes a new person for the tax office to read.

Where did your parents live when they set up their trust, and where do you live now? Share it here. Another family may be tracing the same two addresses.

Figures are estimates for planning, based on public data. Date read: October 2026.