This is nothing new, or at all sneaky, really.
It's not new because:
If you look at the previous TDM that this one replaced (TDM 05-03-06, last updated in early 2020, and I can't link to it as I'm looking at it behind the ITI paywall), you'll find that it has substantially the same form of words at the outset:
"This manual outlines the tax position where accommodation is made available by an employer to an employee for his or her private use."
It's not at all sneaky because:
This form of words simply reflects the relevant legislation in relation to taxation of benefits in kind (section 118(1) TCA 1997). This charges income tax on the provision of "living or other accommodation" (i.e. all accommodation is in scope for the charge), and provides that sections 112, 114 and 897 will apply to so much of the expense as isn't made good by the employee to the employer, as if the expense had been incurred by the employee and refunded to them by the employer.
Therefore, the value of accommodation provided by an employer will always be chargeable, except to the extent that section 114 applies to allow a deduction i.e. to the extent that the expense incurred in relation to the accommodation relates meets the "wholly, exclusively and necessarily" test. This is why the reference to private use is critical, since by definition private use will not meet the "wholly, exclusively and necessarily" test.