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Irish Revenue Updates Guidance Surcharge on Certain Undistributed Income of Close Companies

24 January 2025

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Approved Changes

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Ireland

Irish Revenue has issued eBrief No. 014/25 concerning updated guidance on the surcharge on certain undistributed income of close companies, Tax and Duty Manual Part 13-02-05. Section 440 TCA 1997 provides for an additional charge of corporation tax (referred to as a "surcharge") on close companies. The imposition of this surcharge is to discourage the practice of allowing passive non-trading profits of close companies to accumulate, thereby avoiding income tax at the higher rate on distributions from such profits. The updated guidance provides new and updated examples on the operation of the surcharge.