Revenue eBrief No. 033/25

05 February 2025

Provisions relating to the residence of individuals

Tax and Duty Manual Part 34-00-01 – Provisions Relating to Residence of Individual has been refreshed throughout and includes the following updates:

• Guidance on the meaning of ordinary residence and its implications with respect to the charge to tax have been consolidated into a new paragraph 2.
• Guidance on split year residence has been removed from the manual as detailed guidance on this matter is now provided in a new Tax and Duty Manual Part 34-00-11 (see below for more details).
• A new paragraph 5 has been included to provide more detailed guidance on the charge to tax of income from a public office or employment.
• Paragraph 6 (PAYE Exclusion Orders) has been removed as detailed guidance on this topic is available in Tax and Duty Manual Part 42-04-01 – PAYE Exclusion Orders.
• A new paragraph 7 has been included to provide guidance on double taxation agreements.
• Appendix 1 has been amended to include a summary table outlining the tax implications of an individual’s residence, ordinary residence and domicile status.
• The examples in Appendix 2 have been refreshed and the references in the examples to relevant tax and duty manuals have been updated.
• A new appendix 3 has been included in the manual which contains historical guidance relating to the residence force majeure concession applying to Covid-19 cases in 2020.

Tax and Duty Manual Part 34-00-11 (Split year residence) has been created to provide guidance on split year residence, including the changes introduced by Finance Act 2024.