One consequence of COVID-19 travel restrictions was that an Irish resident company with foreign directors could no longer be sure they would be able to attend board meetings in person.  For purposes of corporate residence, the company may have relied on those directors flying to Ireland for meetings to maintain "central management and control" in Ireland.

Helpfully, Irish Revenue published concessionary measures early on in the pandemic which permitted a modified application of the corporate residence test in this situation.  If a director of a company would have been present in Ireland were it not for COVID-19 travel restrictions, Irish Revenue agreed they would disregard the director's presence outside Ireland. 

Since the relaxation of travel restrictions into Ireland from 19 July 2021, it has not been totally clear that the concessionary treatment continued to apply going forward.  However, on 27 October 2021, Irish Revenue updated their website to say the concessionary treatment does remain valid but only until 31 December 2021, at which time it will be withdrawn.  This provided welcomed clarity on an issue of practical importance for many Irish companies and funds.

It should be noted that the foreign director must maintain a record of the facts and circumstances of their bona fide relevant presence outside Ireland.  That record must be given to Revenue, if requested, as evidence that the presence resulted from COVID-19 related travel restrictions.