Revenue eBrief No. 55/17

02 June 2017

Surcharge on certain undistributed income of close companies

Tax and Duty Manual Part 13-02-05  which deals with the close company surcharge under section 440 TCA 1997, has been updated.

The Manual explains that capital allowances are not deductible against estate and investment income for the purposes of the close company surcharge. For the avoidance of doubt on the matter, it has been updated to clarify that this does not affect the availability of a deduction for capital allowances, which are by virtue of section 307 TCA 1997 treated as a trading expense of the trade, when computing income for the purposes of section 434 TCA 1997.