Revenue has updated its guidance to explain that while capital allowances are not deductible against estate and investment income for close company surcharge purposes, capital allowances are still allowed as a deduction when calculating the income for corporation tax purposes under section 434 TCA 1997 given that section 307 TCA 1997 treats them as a trading expense of the trade.

Revenue eBrief No. 55/17 contains further details and is published here.