The Tax Treatment of Highly Skilled Individuals Rules, 2026 has introduced revised criteria for benefitting from a 15% tax rate on qualifying employment income.
In terms of L.N. 20 of 2026, with effect from 1st January 2026, highly skilled individuals holding an eligible office* in terms of a qualifying contract of employment working within the following sectors, may elect to be subject to tax at 15% on the respective remuneration:
- Financial Services
- Gaming
- Transport - Aviation and/or Maritime
- Offshore Oil and Gas Ancillary
- Science, technology, engineering, and mathematics
- Family offices, back offices, and treasury management operations
The beneficial tax rate of 15% applies to individuals who have the requisite qualifications and at least 5 years of professional experience in the respective field, earning employment income of at least €65,000 from the respective employment/office. The benefit is applicable for a period of 5 years, commencing in the year in which a formal determination is issued, and may be extended for an additional two periods of 5 years each, subject to the respective conditions being maintained.
Applications are open for a 10-year period starting from 1st January 2026 till 31st December 2035.
These rules are set to replace the following existing programmes:
- Highly Qualified Persons Rules.
- Qualifying Employment in Innovation and Creativity (Personal Tax) Rules.
- Qualifying Employment in Aviation (Personal Tax) Rules.
- Qualifying Employment in Maritime Activities and the Servicing of Offshore Oil and Gas Industry Activities (Personal Tax) Rules.
- Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules.
No further benefit may be availed of under the above-mentioned programmes after year of assessment 2030. Beneficiaries under such programmes may transition to the new rules by submitting a formal application to the respective competent authority by 31 December 2028.
* Eligible office - an employment or office where the employment, office, employee or the employer, or any combination thereof, is regulated, licensed or recognised by a competent authority referred to in the Schedules.
