Indecon Review of the Taxation of Share-Based Remuneration - Report

Sep 19, 2026

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Indecon Review of the Taxation of Share-Based Remuneration provides an independent assessment of the taxation framework for share-based remuneration (SBR) in Ireland. Prepared for the Department of Finance, it examines the policy rationale and structure of Irish SBR schemes, participation and scheme design, and how taxation is handled in competitor countries. The review evaluates stakeholder perspectives, considers revenue and employer PRSI forgone, assesses benefits and impacts, and concludes with findings and recommendations for tax and welfare policy.

LanguageEnglish

CategoryGeneral

FormatPDF

Pages87

Reading Time30 min

AccessFree to download

Glossary of Terms and Abbreviations

Executive Summary

Share-Based Remuneration Framework in Ireland

Introduction

Policy rationale

Overview of Irish Share-Based Remuneration Schemes

Summary of Key Findings

Use of Share-Based Remuneration in Ireland

Introduction

Participation in Share-Based Remuneration

Scheme Details

Summary of Key Findings

Share-based Remuneration Schemes in Competitor Countries

Introduction

Tax Treatment of Share-Based Remuneration

SME Schemes

Other Issues

Views of Tax Advisers Consulted

Summary of Key Findings

Stakeholder Perspectives

Introduction

Views on Current Legislation

Feedback on KEEP

Views of Tax Advisors

Summary of Key Findings

Evaluation of Schemes

Introduction

Revenue and Employer PRSI Foregone

Benefits of Share-Based Remuneration Schemes

Summary of Key Findings

Key Findings and Recommendations

Introduction

Recommendations of the Commission on Taxation and Welfare

Recent Tax and PRSI Policy Developments

Competitiveness and Wider Considerations

Key Findings

Recommendations

Conclusions

Annex 1 Stakeholder Workshop Feedback

Indecon Review of the Taxation of Share-Based Remuneration Report Submitted to Department of Finance Prepared by Indecon International Research Economists [www.indecon.ie](www.indecon.ie) 19 July 2024 Glossary of Terms and Abbreviations i Executive Summary i 1 Share-Based Remuneration Framework in Ireland 1 1.1 Introduction 1 1.2 Policy rationale 1 1.3 Overview of Irish Share-Based Remuneration Schemes 2 1.4 Summary of Key Findings 11 2 Use of Share-Based Remuneration in Ireland 13 2.1 Introduction 13 2.2 Participation in Share-Based Remuneration 13 2.3 Scheme Details 19 2.4 Summary of Key Findings 24 3 Share-based Remuneration Schemes in Competitor Countries 25 3.1 Introduction 25 3.2 Tax Treatment of Share-Based Remuneration 25 3.3 SME Schemes 28 3.4 Other Issues 33 3.5 Views of Tax Advisers Consulted 37 3.6 Summary of Key Findings 39 4 Stakeholder Perspectives 40 4.1 Introduction 40 4.2 Views on Current Legislation 40 4.3 Feedback on KEEP 47 4.4 Views of Tax Advisors 48 4.5 Summary of Key Findings 50 5 Evaluation of Schemes 51 5.1 Introduction 51 5.2 Revenue and Employer PRSI Foregone 51 5.3 Benefits of Share-Based Remuneration Schemes 53 5.4 Summary of Key Findings 57 6 Key Findings and Recommendations 59 6.1 Introduction 59 6.2 Recommendations of the Commission on Taxation and Welfare 59 6.3 Recent Tax and PRSI Policy Developments 60 6.4 Competitiveness and Wider Considerations 60 6.5 Key Findings 61 6.6 Recommendations 63 6.7 Conclusions 68 Annex 1 Stakeholder Workshop Feedback 70 Tables, figures and boxes Table 1.1: Summary of Approved Schemes Table 1.2: Summary of Main Unapproved Schemes Table 2.1: Comparison of Share Based Remuneration and National Wage Bill (€m) Table 2.2: Value of SBR Schemes (€m) Subject to PAYE by Firm Size Table 2.3: Value of Selected SBR Schemes by Firm Size (2022) Table 2.4: Number of Employers Administering SBR Schemes by NACE Sector Table 2.5: Value of SBR Schemes (€m) Subject to PAYE by NACE Sector Table 2.6: Number of Employers Administering SBR Schemes by Country of Headquarter Table 2.7: Value of SBR Schemes (€m) Subject to PAYE by Country of Headquarter Table 2.8: Statistics on KEEP Participation in Ireland Table 2.9: Number of KEEP1 Returns Filed by Firm Size Table 2.10: Number of KEEP1 Returns Filed by NACE Industry Sector Table 2.11: Statistics on SAYE schemes Table 2.12: Statistics on APSS Table 2.13: Statistics on Unapproved Share Options Table 2.14: Number of Employers and Employees Participating in Employer's Share Awards Table 2.15: Total Market Value (€m) Table 3.1: Qualifying criteria for Italian tax-favoured schemes Table 3.2: Summary of international comparison of targeted SME schemes Table 3.3: Summary of international comparison of social security contributions, valuation methodologies and personal income tax rates Table 3.4: Summary of views on international comparisons Table 4.1: Summary of Stakeholder Submissions Table 5.1: Income tax and Employer PRSI Foregone (€m) from Share-Based Remuneration Table 5.2: Breakdown of Income Tax Foregone (€m) by Scheme Table 5.3: Breakdown of Employer's PRSI Foregone (€m) by Non-PAYE Scheme Table 5.4: Employer's PRSI Foregone (€m) by Firm Size (PAYE) Table 5.5: Companies Utilising Share-based Remuneration – Assessment of Benefits and Impacts Table 5.6: Impact on Turnover of Share-Based Schemes in the UK Table 5.7: Continued Relevance of Irish Tax Incentive for Share Based Renumeration Table 6.1: Key Findings Table 6. 2: Recommendations Figure 2.1: Number of Employers Administering SBR Schemes Subject to PAYE by Firm Size Figure 2.2: Value of SBR Schemes (€m) Subject to PAYE by NACE Sector Figure 2.3: Number of Employers Administering SBR Schemes by Company Ownership Figure 2.4: Value of SBR Schemes (€m) Subject to PAYE by Company Ownership Figure 4.1: How important or other

FAQs

What is the purpose of the Indecon review?

The report provides an independent review of the taxation framework for share-based remuneration in Ireland for the Department of Finance, including international policy developments and evaluation of consultation submissions.

What aspects of Irish share-based remuneration schemes are covered?

It covers the Irish SBR framework, policy rationale, scheme overview, participation, scheme details, and key findings summarizing evidence from the Irish context.

How does the report evaluate the impact of SBR schemes?

It evaluates revenue and employer PRSI forgone, benefits of SBR schemes, stakeholder perspectives on legislation and support systems, and then presents key findings and recommendations.

Sep 19, 2026

Upload by Jacob