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 distribu…