The Special Assignee Relief Programme (SARP) was introduced in Budget 2012 as part of a strategy to promote Foreign Direct Investment into Ireland, and to allow us to compete internationally to attract highly skilled and mobile executives who act as key decision makers within organisations.
The measure provides income tax relief on a portion of income earned by employees, who are assigned by their employer to work in Ireland, and who previously worked abroad for that employer for a minimum of six months. There is no exemption or relief from USC, and PRSI is payable where the individual is not liable to social insurance contributions in the home country. The minimum salary level applicable to the Scheme is €75,000 per annum, excluding all bonuses, commissions or other similar payments, benefits, or share based remuneration.
Due to variable elements involved, it is not possible for my Department or Revenue to provide a projected cost for the relief for 2019 which could be relied upon for accuracy. I am advised by Revenue that 2016 is the latest year for which data are currently available on SARP. The cost of the scheme in that year was €18.1 million in respect of 793 individuals. On that basis, it can be assumed that the average benefit accruing to participants in the scheme for the year 2016 was €22,824.72.
Revenue have advised me that, according to their records, there were 249 unique employer register numbers recorded by the companies which submitted a SARP employer return in 2016. However, it must be noted that companies can operate different branches under several employer register numbers and that associated companies will also be counted separately.
Finally, as the Deputy may be aware, following on from concerns I had regarding the increasing cost of the incentive, I amended the SARP legislation in Finance Bill 2018 to reinstate an upper salary threshold at the level of €1 million. This change came into effect for new entrants to the programme from 1 January 2019 and for existing beneficiaries of the programme from 1 January 2020.
In accordance with the Department of Finance Tax Expenditure Guidelines, SARP is currently the subject of an independent review, carried out by Indecon Economic Consultants, this year. The review exercise affords an opportunity to look at all elements of the relief and it also includes consultation with all relevant stakeholders.