17 Feb 22
Special Assignee Relief Programme (SARP) - Deadline
The Special Assignee Relief Programme (SARP) was introduced in Ireland on 1 January 2012. The programme was designed to encourage multinational companies to relocate key employees to Ireland. Qualifying employees are eligible to claim to have a proportion of their employment earnings disregarded for income tax. SARP relief may be claimed for a maximum of five consecutive years.
In order to qualify for SARP, a company must be incorporated and a tax resident in a country with which Ireland has either a double taxation agreement or a tax information exchange agreement.
In order to qualify to for SARP, an employee must meet the following criteria:
Arrived in Ireland since 2012, at the request of their employer to perform duties in Ireland for that employer, or with an associated company;
Immediately prior to relocation to Ireland, worked for the company, or with an associated company outside of Ireland for a minimum of six months;
Perform duties for a minimum of 12 consecutive months from the date of relocation;
Have not been an Irish tax resident for the last five years prior to relocation;
Be a tax resident in Ireland for all years for which SARP is claimed;
Earn a minimum basic salary of €75,000 per annum, excluding all bonuses, commissions, benefits, share-based remuneration or other such compensation.
Employers must submit a Form SARP1A for each employee to Revenue, within 90 days of the employee arriving in Ireland.
Calculating applicable relief
SARP deductions for income tax are calculated based on the following formula
(Total Remuneration* - €75,000**) X 30%
Total Remuneration for relief calculation purposes includes all income from the employment (e.g. bonuses, commission or other similar payments, benefits in kind and share based remuneration).
** The annual threshold of €75,000 is pro-rated in years of arrival/ departure.
In 2019, an earnings cap of €1 million was introduced.
Relief may be claimed either through payroll or through a year-end tax return. However, in either case the employee must be registered for SARP within 90 days of their arrival.
Qualifying employees are also eligible for the following benefits provided at their employer’s discretion:
One tax-free trip home per annum
Tax free school fees for children, capped at €5,000 per child, per annum
Annual Reporting Requirement
The employer must complete and file a SARP Annual Return. The Annual Return must be made on or before 23 February after the end of each tax year.
In practice, employees and employers may experience a number of challenges when applying for SARP relief. These challenges include a short-window for application and a complex calculation and reporting process, particularly where remuneration packages for qualifying employees include share-based incentives and are eligible for foreign tax credits.