Revenue eBrief No. 020/21

05 February 2021

Company Residence - End of Transition Period

Section 23A of the Taxes Consolidation Act 1997 sets out rules for determining company residence in the State.

Section 23A was amended by Finance Act 2014, but the application of the amended section 23A was subject to a transition period for companies incorporated before 1st of January 2015. This transition period ceased on 31st of December 2020 and the Tax and Duty Manual Part 02-02-03 has been updated to reflect this.