Concessions made for Corporation Tax

Presence of individuals in, or outside, the State

An employee, director, service provider or agent, may have been restricted from travel between tax jurisdictions because of COVID-19. As a result, they may have had an unavoidably extended presence in the State, or another tax jurisdiction.

Revenue will disregard such presence for Corporation Tax purposes for a company where the employee, director, service provider or agent, was:

  • present in the State when they would have otherwise been present in another jurisdiction
  • present in another jurisdiction when they would otherwise have been present in the State.

The individual and the company must maintain a record of the facts and circumstances of the bona fide relevant presence in, or outside, the State.

This record must be given to Revenue, if requested, as evidence that the presence resulted from COVID-19 related travel restrictions. This treatment remains valid until 31 January 2022. The position will be kept under review to determine whether any further extension is required.