On February 5, 2021, Irish Revenue published an eBrief No. 020/2021 on corporate residence.
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 January 1, 2015.
According to the eBrief, the transition period ceased on December 31, 2020, and the Tax and Duty Manual Part 02-02-03 has been updated to reflect this.
See eBrief No. 020/2021