Special Assignee Relief Programme (SARP) explained

SARP was originally introduced in 2012 as a key component of Ireland’s Foreign Direct Investment (FDI) strategy. The aim of the relief is to reduce the cost to employers of assigning skilled individuals in their companies from abroad to take up positions in the Irish-based operations of their employer, thereby potentially creating more jobs and facilitating the development and expansion of businesses in Ireland.

Since its introduction, Revenue have amended the legislation several times and also clarified conditions where uncertainty was present. Employers should ensure that they are aware of potential pitfalls and professional advice is recommended well in advance of an employee coming to Ireland. One particular issue to be conscious of is the number of days the employee has spent in Ireland prior to their coming to Ireland on a full-time basis.

SARP was due to expire for new entrants on 31 December 2025. However, in the Budget 2026 announcement in October 2025, this relief was extended for a further five years until 31 December 2030.

Overview of the relief

SARP provides for income tax relief on a proportion of income earned by an employee who is assigned by his or her relevant employer to work in Ireland for that employer or for an associated company of that relevant employer in Ireland.

Where certain conditions are satisfied, an employee can make a claim to have a proportion of his or her earnings from the employment with the relevant employer or with the associated company disregarded for income tax purposes.

For 2023 to 2025, the proportion is determined as 30% of an employee’s income over €100,000. For new entrants from 1 January 2026, the income threshold will increase to €125,000. An upper income threshold of €1 million also applies for all claimants.

Income which is disregarded income for income tax purposes is not exempt from the charge to USC or PRSI.

What are the main conditions that must be satisfied to avail of SARP?

Please note that the following are “headline” conditions only and are not exhaustive. For example, under Criterion (2) below, where an employee performs some duties of their employment in Ireland prior to their permanent arrival date, then they would not qualify for SARP. However, Revenue do allow a minor number of days for work purposes and for personal purposes in the six-month period prior to arrival.

The main conditions for assessing SARP eligibility are:

1. Employees must be assigned by their overseas employer to work in Ireland for that employer or for an associated company in Ireland.
2. The employee must previously have worked for their overseas employer for a minimum period of 6 months immediately before arriving in Ireland.
3. The foreign employer must be a company incorporated and tax resident in a country with which Ireland has a double taxation agreement or a tax information exchange agreement.
4. The employee must not have been tax resident in Ireland for the previous 5 tax years before arriving in Ireland.
5. The employee must be tax resident in Ireland for all years for which the relief is claimed.
6. The employee must work in Ireland for a minimum period of 12 months. If an assignee does not perform any employment duties in Ireland in any one of the individual months in this period, he or she will fail to fulfil this requirement and will not trigger his or her first entitlement to the relief.
7. For new entrants up to 31 December 2025, the employee must earn a minimum basic salary of €100,000 per annum, excluding all bonuses, benefits or share based remuneration. For new entrants from 1 January 2026, the minimum basic salary will increase to €125,000 per annum.
8. The individual’s relevant employer or associated company must certify, within 90 days of the employee’s arrival in Ireland to perform duties of his/her employment, that the individual satisfies the conditions above.
   The Finance Bill 2025 proposes to relax the above rule slightly from 1 January 2026. If the application to Revenue is made greater than 90 days but under 180 days after the employee arrives in Ireland, the SARP eligibility will be limited to four years of relief instead of the standard five years, with this relief commencing in the year after arrival, instead of the year of arrival.
9. The employee must obtain a Personal Public Service Number (PPSN).

In addition to international assignees, returning Irish citizens may also avail of the relief provided all other conditions are fulfilled.

Certain other tax reliefs (e.g. the remittance basis for foreign sourced employment income), the Foreign Earnings Deduction (FED), and the Research & Development Relief (R&D) may not be claimed if SARP relief is claimed.

How is the SARP relief calculated?

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, for example:

Example: 2025

Elaine is a relevant employee who earns €180,000 in 2025. Relief is calculated as follows:

A - B x 30% = relief due, where:
A = €180,000, B = €100,000 (annual threshold) 
           (€180,000 - €100,000) x 30% = €24,000

While €24,000 of Elaine's income is relieved from tax, it remains liable to the USC and, depending on Elaine's circumstances, may also be liable to PRSI.

Elaine's marginal tax rate is 40%.

€24,000 x 40% = €9,600

Relief due for 2025 is €9,600

Example: 2026

Joe is a relevant employee who earns €180,000 in 2026. Relief is calculated as follows:

A - B x 30% = relief due, where:
A = €180,000, B = €125,000 (annual threshold)
            (€180,000 - €125,000) x 30% = €16,500

While this €16,500 is relieved from tax, it remains liable to the USC and, depending on certain circumstances, may also be liable to PRSI.

If Joe’s marginal tax rate is 40%, the relief due would be:
€16,500 x 40% = €6,600

What are the application and reporting requirements to avail of SARP?

Employers must certify to Revenue on the approved form, that an employee meets certain conditions. The certification must be made within 90 days of arrival in Ireland, otherwise the relief will be denied. As outlined above, a reduced claim to relief of four years may apply if this application is made between 90 and 180 days after the arrival of the employee in Ireland.

Employees making a claim will automatically become chargeable persons for the year of the claim, which will result in a tax return filing requirement for the individual.

The employer is also required to submit an annual SARP employer return to Revenue.  The Finance Bill proposes to extend the filing date for the annual end of year employer return to 30 June in respect of the 2025 tax year and subsequent tax years, which would mean that the deadline for filing the 2025 SARP employer return would be 30 June 2026.  The Finance Bill should be signed into law by the end of 2025

If you have any questions in relation to the above, or if you would like to discuss this topic further, please contact a member of the Forvis Mazars employment tax team below: