COVID-19 and Corporation Tax

07 January 2022

As part of its advice and guidance for taxpayers dealing with a range of difficulties caused by the impacts of the COVID-19 virus, Revenue have updated their guidance regarding the presence of individuals in, or outside, Ireland, for Corporation Tax purposes.

Revenue have stated that where an individual is present in Ireland, and that presence is shown to result from travel restrictions related to COVID-19, they will be prepared to disregard such presence in Ireland for Corporation Tax purposes for the employer company.

Similarly, if an individual is present in another jurisdiction as a result of COVID-19 related travel restrictions, and would otherwise have been present in Ireland, Revenue will be prepared to disregard such presence outside Ireland for Corporation Tax purposes.

In both cases, the individual and company should maintain a record of the facts and circumstances of the bona fide relevant presence in or outside of Ireland for production to Revenue if evidence that such presence resulted from COVID-related travel restrictions is requested.

In November 2021, Revenue confirmed that this treatment would remain valid until 31 December 2021, at which time it would be withdrawn. However, they have now confirmed that the concessional treatment is to remain in place until 31 January 2022. The position will be kept under review to determine if any further extension will be required. This is a very welcome development given that the pandemic continues to have a significant impact on cross-border travel. 

BDO Ireland is here to support you and your business through these unprecedented times. For any questions or assistance please contact your usual BDO tax contact or a member of our Tax team