Global Mobility & Employment

New measures not announced in Budget 2026

The Finance Bill provides for the extension of the Special Assignee Relief programme (SARP) for 5 years to 31 December 2030. The provisions for new entrants to the scheme from 1 January 2026 are being amended as follows: 

• A minimum salary of €125,000 will be required to qualify for the relief. 
• A 30% reduction in income subject to income tax between €125,000 and €1 million will be available.
• The employer continues to be required to certify to the Revenue Commissioners within 90 days of the individual’s arrival in Ireland that the individual satisfies the conditions for SARP.  
• If the certification is submitted by the employer after 90 days but within 180 days of the individual’s arrival they will qualify for the SARP relief. However, in these cases where certification is after 90 days but within 180 days of arrival, the individual will only be able to claim SARP for 4 years instead of 5 years. 

In addition, the Finance Bill proposes an amendment of the filing date for the employer annual SARP return from 23 February to 30 June in respect of the 2025 tax year and subsequent years.  

The definition of a qualifying day for Foreign Earnings Deduction (FED) is amended to remove the requirement for an individual to work 3 consecutive days in a relevant country. The relief is extended, as mentioned in the budget, for 5 years to 31 December 2030 and from 1 January 2026 the Philippines and Turkey are included as relevant countries. A further change is a provision that a day will be a qualifying day only where the individual’s presence in the relevant state is reasonably required for the purposes of the performance of the duties of the office or employment.  

The Finance Bill includes amendments to various parts of the legislation to provide that employer contributions under auto enrolment will not be subject to income tax or Universal Social Charge (USC). 

Our view

The Minister for Finance stated in his budget speech that in addition to extending the relief and increasing the base salary requirement he would also simplify the administrative requirements. The proposed amendment which allows for individuals to qualify for the relief if the employer certification is submitted after 90 days but within 180 days is not, in our view, a simplification.  It is disappointing that the challenges the 90 day certification requirement pose for individuals and employers have not been fully recognised and that a delay would cause the loss of a full year’s SARP relief. It would have been preferable to consider whether the 90 day requirement is necessary at all and potentially remove it so as to simplify the relief. In order to meet the “relevant employee” conditions, one of the elements the employer has to certify is that the individual has obtained a PPS number. We believe that the absence of a PPS number in the first 90 days should not be a barrier to claiming SARP and it is disappointing that this has not been removed. 

The extension of FED for 5 years, the increase in the maximum relief from €35,000 to €50,000 and the removal of the 3 consecutive days requirement are welcome changes.  However, the provision that a day can only be qualifying if the individual’s presence is reasonably required for the purposes of the performance of the duties of the office or employment may be problematic unless there is clear guidance as to what would be regarded as “Reasonably required”.   

Pension Auto Enrolment is due to commence from 1 January 2026.  The proposed amendments to confirm that employer contributions are not subject to income tax and USC are welcome. The National Automatic Enrolment Retirement Savings Authority (‘NAERSA’) was founded on 14th October 2025. Employers need to ensure that they are prepared for the roll out of Auto Enrolment, including registering via the MyFutureFund portal when it becomes available later this year.  A clear process for managing the requirements of Auto Enrolment, including the employee communication requirements, should be established.