Welcome to the Share | Updates – September 2026 edition!
This month, we are sharing tax and legal updates from Argentina, Denmark, Ireland, and Netherlands.
CMS Employee Equity 101 – Challenges and Opportunities of Granting Employee Equity to a Global Workforce.
Private but Global – Some thoughts from ProShare 2026.
Recent Changes
Argentina
Social Security Relief for Equity Compensation
Argentina has adopted two measures that reduce employer costs. One of them applies directly to equity compensation.
Equity compensation exclusion (Law 27.802 and Decree 407/2026)
Decree 407/2026, published on 29 May 2026, regulates the labor modernization framework. It confirms certain benefits from stock options, share grants and similar instruments may be excluded from the social security contribution base, subject to conditions.
The exclusion is not automatic and applies only if the legal requirements are met. It affects social security contributions only, and income tax treatment is unchanged.
The CMS team is looking into this topic with the local lawyer and we’ll come back with more details.
Denmark
7P Scheme Expansion
The Danish Section 7P regime has been expanded for qualifying growth companies from 1 July 2026. Key changes include:
- the company age limit increasing from 5 to 10 years;
- the employee threshold increasing from 50 to 150 employees;
- the annual turnover or balance sheet threshold increasing from DKK 15 million to DKK 200 million;
- removal of the previous restriction on the value of awards for qualifying companies; and
- a reduction in valuation requirements when granting awards.
Ireland
Pay Related Social Insurance (PRSI) Rate Increase
On 1 October 2026, all PRSI contribution rates will increase by 0.15%. For example, Employee Class A PRSI will increase from 4.2% to 4.35%.
Awards that are settled in shares are not generally subject to Employer PRSI. To the extent that an Award is settled in cash, Employer PRSI may be payable by the Local Company, up to a maximum rate of 11.4% (uncapped).
Netherlands
Proposal of a New Employee Share Option Regime for Start-ups
On 15 September 2026, the Dutch government submitted its 2027 Tax Plan package to Parliament. It also includes the Fiscal Incentives for Start-ups and Scale-ups Act, which would create a dedicated tax regime for employee share options at qualifying companies.
Who qualifies:
A company must run a scalable, repeatable, innovation-based business model, must not be listed on a regulated market, and must have no more than 25% of its shares held by a listed entity. It would also need an RVO (Netherlands Enterprise Agency) decision confirming its status, valid for up to 23 years in total.
Key features:
- Later tax point: Tax would arise when the shares are sold rather than when they become tradable. Employees could elect earlier taxation.
- Lower tax base: Only 65% of the gain on sale, after deducting the exercise price, would be subject to wage tax, an effective rate of around 32%. This applies only to the value increase above the fair market value at grant.
- Holding period: Two years would apply between grant and sale of the shares.
- Broader scope: Options over parent company shares and over share certificates would also qualify, provided the parent and the Dutch subsidiary each hold an RVO decision.
Timing:
The proposed start date is 1 January 2027, conditional on European Commission State aid approval. Subject to transitional rules, the regime is intended to apply retroactively to options granted on or after 17 April 2025, provided no wage tax has been levied on them by 31 December 2026. The cabinet is a minority government, so amendments during the parliamentary process are possible.
Private but Global – Some Thoughts from ProShare 2026
Increasingly, private, unlisted companies have international employees, and want to offer equity.
At the ProShare 2026 Conference in London, we were invited to discuss the challenges of equity tax and legal compliance from a private company perspective. Our CEO Dave Quick chaired the panel, and our client Joe Kohler from the frontier tech company Nethermind shared his experiences managing over 200 employees across 60 jurisdictions. Andy Quayle from CMS provided the legal perspective.
It was an insightful discussion, and we will be featuring some of the learnings in depth soon on our website.
Many thanks to Joe and Andy, and to ProShare for an excellent conference.
CMS Employee Equity 101 Series
Challenges and Opportunities of Granting Employee Equity to a Global Workforce
Make sure you didn't miss the answers to very practical challenges for companies operating share plans internationally:
- Can I grant equity to my employees overseas?
- Can I…ignore local laws when granting equity to my overseas employees?
- Can I leave the tax to my overseas employees?
You can subscribe to these insights here.
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- Expert guidance on legal compliance and taxation
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