Welcome to the Share | Updates November edition!
Recent Changes Find out about EU Works Council Directive and changes in Cambodia, China, Finland, Ireland, Lithuania, Malta, Netherlands, Nigeria, Oman, Singapore and UK.
Did You Know? Let’s take a closer look at the UK’s tax-advantaged share plan regimes. This month, we’ll begin with one of the two plans that must be offered on a non-discretionary basis, meaning they’re designed for all employees: the Save As You Earn (SAYE) scheme.
Periodic Reminders Upcoming deadlines for annual returns, statements, reports, notifications and filings you can expect over the next three months.
Recent Changes
EU
Revised European Works Council Directive
The Council of the EU has revised the existing Directive 2009/38/EC on European works councils (EWCs).
The Directive will enter into force upon its publication in the Official EU Journal. Members will have two years to transpose the Directive into law and 3 years from entering into force, to apply the provisions.
EWC’s are bodies that perform the role of informing and consulting the workers of multinational companies that have at least 1000 employees operating in at least two EU or European Economic Area (EEA) countries.
The Directive introduces a broader definition of “transnational matters.” Any measure that affects employees in more than one Member State is now considered transnational. Changes to employee share plans are more likely to require EWC information and consultation.
This 2025 revision may expand the obligations of multinational employers when implementing or changing employee share plans.
Cambodia
New Capital Gains Tax Rate from 1 January 2026
A new rate of Capital Gains Tax at 20% will apply from 1 January 2026. The CGT applies to six types of assets: leases, investment assets, goodwill, intellectual property, foreign currencies, and immovable property.
China
Social Security Cap Increased in Beijing and Shanghai
On 18 September 2025, the Ministry of Human Resources and Social Security of Beijing and Shanghai announced the updated upper and lower salary bases for all social insurance contributions for 2025. Here are the caps for both cities, effective from July 2025:
- Beijing upper limit: RMB 35,811/month
- Shanghai upper limit: RMB 37,302/month
Employers may pay any resulting differences by the end of December 2025, with no late payment fees charged during this period.
Finland
Proposal to Reduce the Highest Marginal Personal Income Tax Rate
The government proposal for 2026 suggests that the highest marginal tax rates on earned income taxation would be reduced to around 52 percent.
Currently, the personal income tax is composed of the state income tax (progressive, with the top bracket for residents taxed at 44.25%), and the municipal income tax (between about 4.70% and 10.90%). It can also include church tax, that adds typically 1%–2.25%. Therefore, earned income tax is payable up to a maximum rate of 57.4%
Ireland
The Upper Limit for the 2% Universal Social Charge Rate Increase
The upper limit for the second rate of 2% Universal Social Charge (USC) rate shall increase to €28,700 in 2026.
Due to the increase of the minimum salary from 1 January 2016, the USC ceiling had a corresponding increase, to ensure that workers on the new minimum wage are not taxed at the higher USC rate.
Extension of Foreign Earnings Deduction (FED)
The Foreign Earnings Deduction (FED), first introduced in 2012, is designed to support Irish businesses expanding into emerging markets by offering income tax relief to employees who travel abroad to certain countries for work.
The FED provides tax relief to Irish tax resident employees who temporarily travel to certain countries to carry out duties related to their employment. The amount of relief available is based on the number of qualifying days the employee spends working in these particular countries.
Originally set to expire at the end of 2025, the Finance Bill confirms that the FED will be extended by five years, until 31 December 2030.
Also, effective from 1 January 2026:The maximum amount of qualifying employment income will increase from €35,000 to €50,000, and The Philippines and Türkiye will be added to the list of qualifying countries.
In addition, the requirement for employees to spend three consecutive days working in a qualifying country in order to qualify for the FED has been removed, which is a welcome change.
Capital Gains: Revised Entrepreneur Relief
Ireland will increase the lifetime limit for the 10% capital gains tax rate on qualifying business asset disposals to €1.5 million (from €1 million), effective for disposals on or after 1 January 2026, enabling entrepreneurs to benefit from the 10% rate on an additional €500,000 of lifetime gains.
Lithuania
Capital Gains Tax Exemption Extended
Sales of participation interests in foreign limited liability companies now qualify for Lithuania’s capital gains tax exemption (aligning foreign share disposals with the domestic participation exemption).
Malta
Flat 15% Income Tax Rate for Qualifying Senior Employees
Malta has introduced a flat 15% income tax rate for qualifying senior employees in family office, back‑office, or treasury management roles, aimed at attracting high‑skilled professionals. The regime applies from 1 January 2025, by application, and can be claimed for up to 15 years. Eligibility requires annual remuneration of at least €65,000 and satisfaction of specified experience or qualification criteria.
Netherlands
The Employer’s Disability Insurance Fund (AOF) Increases
The employer’s disability insurance fund (AOF) contribution will increase by 0.08% in 2026 to offset other tax measures. The AOF is a mandatory employer payment funding national invalidity insurance.
Nigeria
Capital Gains Tax Expected to Change from January 2026
From January 2026, the rate of CGT in Nigeria is expected to change from a flat rate of 10% to the same rate as that applying to the taxpayer’s income tax (potentially up to 25%).
Singapore
Tax Deduction for Newly Issued Shares
On 30 September 2025, the Inland Revenue Authority of Singapore (IRAS) released the fourth edition of its e-Tax Guide regarding tax deduction for shares used to fulfill obligations under an Employee Equity-Base Remuneration (EEBR) scheme.
The scope of deduction has been expanded, to include payments for newly issued shares (not just treasury shares). It takes effect from the year of assessment 2026, for income earned in the year 2025.
In order for the Local Company to be able to claim a deduction, the costs will need to be recharged to the Local Company (under a written agreement).
The deduction regime now covers all share types used to fulfill obligations under EEBR schemes: treasury, previously issued, and newly issued shares.
Oman
Introduction of Personal Income Tax from January 2028
Oman has enacted a personal income tax effective from 1 January 2028, imposing a 5% tax on individuals with annual income above OMR 42,000 (approximately USD 109,000).
Taxpayers exceeding the threshold must file an electronic return on the prescribed form within six months of the tax year end (by 30 June of the following year) and pay the corresponding tax; where an individual’s only income comprises salaries, wages, board membership allowances or retirement pensions from a single employer, the employer may, upon request, file the annual return on the individual’s behalf.
UK
Enterprise Management Incentives (EMI) Company Eligibility Expansion
The Chancellor’s Autumn Budget was published on 26 November 2025.
The new budget is supporting companies to scale and stay in the UK, so that the growth benefits can be fully captured in the UK. So far, tax incentives have been successful at supporting start-ups. The government announced a package of tax changes to also support scaling companies to attract investment and talent.
The government will increase the following eligibility conditions for companies, from April 2026:
- Employee limit: increasing from 250 to 500
- Gross assets limit: increasing from £30 million to £120 million
- Company option limit: increasing from £3 million to £6 million
- The maximum holding period will increase to 15 years including in respect of existing EMI contracts (previously, options had to be exercised within 10 years of being granted).
This will be legislated in the Finance Bill 2025-26.
The EMI notification requirement will also be removed from April 2027. This will be legislated in Finance Bill 2026-27.
EMI and Company Share Option Plan (CSOP) Private Intermittent Securities and Capital Exchange System (PISCES) Reform
The government will allow existing EMI and CSOP contracts to be amended to include PISCES as an exercisable event. This change will be included in the Finance Bill 2026–27. The legislation applies to contracts agreed before 6 April 2028, and the changes take effect retrospectively from 15 May 2025.
Did you Know?
In the UK, there are four main tax-advantaged employee share plans:
- Save As You Earn (SAYE)
- Share Incentive Plan (SIP)
- Company Share Option Plan (CSOP)
- Enterprise Management Incentives (EMI)
Save As You Earn scheme (SAYE) – a snapshot
Description
- The company grants options to the employees to acquire shares at an exercise price.
- The participant must enter a savings contract (monthly payroll deductions from post-tax salary), which accumulates the funds used to buy the shares.
Exercise Price
- It may be discounted by as much as 20% of the market value of the shares at the grant date.
Can it be Discretionary?
- No, all employees must be invited(a minimum qualifying period of service may apply)
Eligibility for the Company (the shares must be ordinary shares, fully paid up, and non-redeemable)
- The company must self-certify to HMRC that the SAYE Plan meets the statutory requirements
Eligibility for Employees
- Must be offered to all employees with at least 5 years of service
- May be offered to employees with less service.
Time Considerations
- 3 or 5 years holding period (depending on the savings contract)
Grant Limits for Employees
- Employees can save from £5 up to £500 a month.
Tax Advantages – Employee
- Grant: No tax
- Exercise: Generally no income tax on exercise
- Sale: CGT is taxed on the difference between the share value at sale and the savings amount invested into the plan
No CGT if the shares are transferred:
- to an Individual Savings Account (ISA) within 90 days of taking them out of the scheme
- to a pension, directly from the scheme when it ends
Corporation Tax Deduction from Company Profits
- The amount of option gains realized by its employees
- The scheme setup and administration costs
Periodical Reminders
China
SAFE Foreign Exchange Quota Renewal – December 31
Companies registered with the State Administration of Foreign Exchange (SAFE) in China are required to file their quarterly reports electronically.
Saudi Arabia
Notify CMA all offers of Awards made in the preceding quarter – January 10
Companies offering Awards to employees in Saudi Arabia must notify the Capital Market Authority (CMA) within ten days after the end of the quarter following grant disclosing the total number and value of all offers made to employees during the preceding quarter.
Philippines
Annual report to the SEC in respect of Awards – January 10
Once the Plan has been granted a registration exemption by the SEC, the Company and Local Company are required to submit to the SEC, on or before the 10th of January of each year following the date of the grant until full issuance of the Award under the Plan, a report containing the necessary details of the grant. This should include details such as the names of the Participants and the number of shares subscribed by them in accordance with the Securities Regulation Code and its Implementing Rules and Regulations.
Thailand
Annual report to the SEC in respect of Awards – January 15
There is an annual reporting requirement with the SEC in respect of Awards granted in the preceding year.
Vietnam
Quarterly report to the SBV – January 20
There are quarterly reporting requirements to the SBV using a prescribed form which includes details of the number of grants of Awards made and the number of shares issued under Awards.
China
SAFE Quarterly Filing – January 30
Companies registered with the State Administration of Foreign Exchange (SAFE) in China are required to file their quarterly reports electronically.
China
SAFE Foreign Exchange Quota Renewal – December 31
Companies registered with the State Administration of Foreign Exchange (SAFE) in China are required to file their quarterly reports electronically.
Practical insight
It remains essential to monitor practical filing requirements and regulator‑led administration, even where local practice appears to be easing.
In China, Malaysia and the Philippines, authorities are shifting their administrative approaches – some tightening, some relaxing, and others applying rules inconsistently.
Always verify current local practice against the latest regulatory position in each jurisdiction before proceeding.