Irish Revenue has issued eBrief 020/21 regarding the end of the transition period for changes introduced by the Finance Act 2014 on the determination of company residence in Ireland. Finance Act 2014 substituted a new section for section 23A to provide that a company incorporated in Ireland will be regarded as resident for tax purposes in Ireland, unless it is treated as resident in a treaty partner country by virtue of a double taxation treaty.
The incorporation rule for determining the t…