The updated guidance clarifies the tax treatment of unapproved share option schemes, which allow employees or directors to purchase company shares at a fixed price within a set timeframe.
Irish Revenue has released eBrief No. 221/25 on 26 November 2025, outlining revisions to its guidance on the tax treatment of “unapproved share option schemes.” These schemes involve situations where a company grants an employee or director the right to purchase a specified number of shares at a set price within a defined time frame.
Share Options – updates to Share Scheme manual
Chapter 3 (Unapproved Share Options) has been updated as follows;
- to confirm the position that it is the employer who is responsible for submitting the tax arising on date of grant of a long option,
- to provide clarification on how to provide credit through payroll on the exercise of a long option for any income tax paid on date of grant, and
- to clarify the amount of a gain to be reported on the Form RSS1 in situations where an individual is only taxable in Ireland on a portion of the share option gain under a Double Taxation Agreement.
In addition, references to indexation on disposal of shares acquired pre-2003 have been removed.
