Tuesday, February 12, 2019
The Irish tax agency has updated its guidance on provisions in Section 825C of the Taxes Consolidation Act 1997 on the Special Assignee Relief Programme.
These Irish tax law provisions provide income tax relief to certain employees assigned to work in Ireland during any of the tax years 2012 to 2020, provided certain conditions are satisfied.
SARP was introduced in 2012. The aim of the program is to reduce the cost to employers of assigning skilled individuals in their companies from abroad to take up positions in their Irish-based operations.
For the 2012, 2013, and 2014 tax years, SARP provided relief from income tax on 30 percent of salary between EUR75,000 (EUR84,458) and EUR500,000. In 2015, the upper salary threshold was scrapped. In 2016, the relief was extended to the end of 2020.
The Revenue Commissioners prepare an annual analysis of SARP. The 2016 report found that the cost of SARP has risen significantly, from EUR5.9m in 2014, to EUR9.5m in 2015, and to EUR18.1m in 2016. This increase is attributed to the removal of the income cap and a rise in the number of very high earners availing themselves of the relief. In light of these findings, the Government decided in 2018 to place a ceiling on eligible income for SARP recipients of EUR1m.
The manual has been updated to include details of this new upper income threshold of EUR1m, introduced in the Finance Act 2018, and also includes: