Dr. Brian Keegan:

No. The Deputy is right that money that is left in a company is frequently invested in property, but that does not extinguish the requirement to distribute profits. As far as the tax system is concerned, it does not care where the profits have gone. They are just undistributed profits. The only commercial situation where the surcharge would not apply would be where there was a company law reason for a distribution not being capable of being made, for example, if the company was insolvent, but we are discussing the extreme edges there. Generally speaking, it does not matter what the company does with the money. It is not absolved of the requirement to pay the surcharge.