The Special Assignee Relief Programme (“SARP”) was first introduced in Finance Act 2012 and was designed to encourage the relocation/assignment of key talent within organisations to Ireland. Successive Finance Acts since 2012 have extended the period of this relief.
The relief applies to those arriving in Ireland in any of the years from 2012 to 2025 inclusive.
Once an individual qualifies for relief, they can avail of it for up to 5 consecutive tax years from their first year of claim. This is subject to ALL of the qualifying conditions outlined below being met in each year of claim.
Qualifying conditions
Revenue has published updated guidance over the years to provide clarity on the prevailing requirements to avail of SARP. In summary, SARP relief can be claimed by an individual who:
The employer must also certify within 90 days of arrival that the conditions to claim the relief are met.
Advance planning
Recent Revenue guidance provided additional clarifications on some of the above qualifying conditions to clarify circumstances where SARP relief would NOT be granted. These include scenarios where:
Careful planning in advance of an employee’s arrival in Ireland is important to ensure this valuable relief is not unintentionally lost.
It should be noted that where the above pre and post-arrival criteria for SARP are not met, the impact for the employee is not limited to the loss of the tax relief under SARP for the first year of the claim but will result in losing the tax relief for every year in which the employee may otherwise have met the criteria to qualify.
How the relief works
The tax relief is granted by way of calculating what is known as “the specified amount” and relieving that specified amount from the charge to income tax.
The specified amount is determined by the following formula:
(A-B) x 30%
A = is the amount of the relevant employee’s income
B = €100,000 (however, where an employee arrives or leaves Ireland during the tax year, B is reduced accordingly).
‘A’ is capped at €1,000,000 for employees claiming the relief for tax years from and including 2020 onwards.
Example John Byrne is employed by a US multinational under a US contract of employment for eight years. On 1 July 2023, John is assigned to the Irish subsidiary and will devote his time to developing the Irish operations. The assignment is expected to last for two years. From 1 July 2023 to 31 Dec 2023, John has the following remuneration package:
*tax relief is available for school fees (subject to certain limits) and travel costs home.
(€171,250 - (€100,000 x 6/12) x 30% = €36,375
John is obliged to submit an annual income tax return (on Form 11) in Ireland each tax year in which he claims SARP. The personal income tax return is due for submission on or before 31 October of the following year. |
Employer reporting requirements
An employer must file a Form SARP 1A for each employee availing of SARP relief. In order to qualify for SARP, this form must be submitted to Revenue within 90 days of the employee’s arrival in Ireland to perform the duties of his or her employment here.
In addition, the employer is required to file a SARP annual return. The annual return must be made on or before 23 February following the end of each tax year.
Employee reporting requirements
An employee availing of SARP Relief is a chargeable person and must file an annual income tax return (on Form 11) using the Revenue Online Service (ROS) by the filing deadline for the relevant tax year (31 October of the following year).
How can BDO help
The BDO Employment Tax Team helps support both domestic and international organisations in dealing with global mobility-related challenges.
We can assist in dealing with all matters relating to SARP, including:
Please contact a member of the BDO in Ireland Employment Tax team for further information and discussion:
Mark Hynes