Welcome to the Share | Updates – January 2026 edition!
As we start the new year, you may be eager to learn about the latest material changes affecting employee share plans worldwide.
Keeping our platform up to date is a constant priority, and we’re pleased to share recent tax or legal changes across the following jurisdictions: Belgium, Czech Republic, Finland, Ireland, Kazakhstan, Lithuania, Nigeria, Spain, Thailand and the UK.
The CMS team is working closely with the local counsel in each country, and additional updates will be rolled out over the coming months as further changes are implemented.
Recent Changes
Belgium
Introduction of Capital Gains from Shares
Belgium has introduced a 10% tax on capital gains from shares, known as the ‘Solidarity Contribution’.
This will be effective in relation to gains from assets (including from the sale of shares) realised on or after 1 January 2026.
There is an annual exemption of EUR 10,000 which may be carried forward for up to 5 years.
Companies and employees should be aware of the potential for additional tax liabilities and increased administrative requirements once the new regime takes effect.
Czech Republic
2026 Tax Changes
Effective 1 January 2026, several reforms have been introduced impacting the taxation of awards in the Czech Republic, including:
- Codification of tax deferral for qualifying plans.
- Changes to social security caps, where social security applies to awards.
- Removal of the CZK 40 million exemption on income from the sale of shares.
Finland
2026 Tax Changes
There have been various tax changes in Finland, effective 1 January 2026, including a cap on the highest rate of marginal tax applying (~50.4%) and unifying pensions contributions, where previously this was determined by age.
The highest marginal tax rate consists of income tax (37.50%), municipal tax (10.9%), and church tax (2.25%).
Note that the maximum possible church tax rate of 2.25% does not apply in the same municipality as the highest municipal tax rate. For this reason, the highest actual tax rate is not simply the sum of the highest individual tax rates.
Ireland
KEEP Regime Extended
The Key Employee Engagement Programme (KEEP), Ireland’s tax-favored share option scheme for SMEs, has been extended until 31 December 2028 (previously set to expire at the end of 2025), subject to EU State Aid approval.
No other changes have been made to the conditions of the KEEP scheme.
Kazakhstan
Key 2026 Tax Changes
Kazakhstan has enacted a new Tax Code, signed on 18 July 2025, introducing significant changes to the taxation of personal income and investment returns. These reforms take effect from 1 January 2026. We’re sharing the changes relevant for employees share plans:
- From 2026, Kazakhstan moves away from its long-standing flat 10% personal income tax (PIT) and adopts a progressive PIT system. Employment income will continue to be taxed at 10% up to a statutory income threshold, with a new top rate of 15% applying to higher income bands.
- Dividend income received by individuals will also be taxed under a progressive structure from 2026. While lower levels of dividend income remain subject to a reduced rate, dividends exceeding the statutory threshold will be taxed at 15%, aligning with the new top personal income tax rate. This represents an increase from the previous flat 10% dividend tax.
- The new Tax Code tightens the treatment of capital gains from the disposal of shares and securities. Gains exceeding certain thresholds, or not qualifying for specific exemptions, will be subject to tax at 15%, compared with the current 10% flat rate.
Lithuania
Capital Gains Tax on Share from Awards
From 1 January 2026, a flat rate of income tax at 15% will apply on any capital gains derived from the share of shares provided those shares have been held for a minimum of three years from the date on which the right to acquire the shares arose.
Nigeria
New Capital Gains Tax Regime
A new regime applies to capital gains tax, with the tax rate being payable at the same rate as the Participant’s liability for income tax (up to 25%). Certain exemptions apply, for example, if the Participant’s capital gains during the year are below applicable thresholds.
Previously a flat rate of 10% applied.
Thailand
Social Security Cap Increased
Effective January 1 2026, the maximum contribution base increased from THB 15,000 to THB 17,500.
Spain
Social Security Cap Increased
Social security cap increased from €4,909.50 to €5,101.20 / month.
Solidarity contribution changes to:
- 1,15% for €5,101.21 – €5,611.32
- 1,25% for €5,611.33 – €7,651.80 euros
- 1,46% from €7,651.80
The Solidarity Contribution is paid by both the employer (as to 83.39% of the liability) and the employee (as to 16.61% of the liability).
UK
New UK Prospectus Regime
The new UK Prospectus Regime came into force on 19 January 2026. Under the new regime, it continues to be the case that offers of securities in the UK are generally subject to a requirement to make available an approved prospectus.
The key exemptions to this requirement relevant to the operation of share awards to employees (the “employee share scheme” exemption and offers to 150 people or fewer) continue to apply. There also continues to be an exemption for offers with a total consideration below a certain threshold, but the threshold has changed from EUR €8 million to GBP £5 million.
Proposed Changes to Tax on Dividends
The “ordinary” and “upper” tax rates for dividends are due to increase by 2%.
In the Budget on 26 November 2025, the Government announced proposed increases in the “ordinary” and “upper” tax rates for dividends. The increases are due to come into effect on 6 April 2026. The “ordinary” rate is set to increase from 8.75% to 10.75%. The “upper” rate is set to increase from 33.75% to 35.75%.
No changes are proposed to be made to the “additional” rate, which is due to remain at 39.35%.
Proposed Improvements to EMI
Various improvements are proposed to the EMI legislation, which will make EMI options available to more companies.
In the Budget on 26 November 2026, the Government announced the following proposed changes to the Enterprise Management Incentives (“EMI”) legislation:
- the limit on company options will be increased to £6 million, from £3 million;
- the limit on gross assets will be increased to £120 million, from £30 million;
- the limit on the number of employees will be increased to 500 employees from 250 employees; and
- the limit on the exercise period for individual EMI options will be increased to 15 years, from 10 years.
EMI is a tax-efficient method to deliver share options to UK-based employees. The proposed changes will increase the ability for companies to offer these Awards.