Country | Primary Scheme | Tax Impact at Grant/Exercise | Holding Period for Tax Benefits | Tax Rate at Sale | Conditions for Early Exercise | Company Size/Issue Limits | Additional Schemes | Eligibility Criteria for Individuals |
---|---|---|---|---|---|---|---|---|
Austria | Deferred tax at sale if company <10 years old; 75% taxed at 27.5%, 25% | |||||||
as income. | No tax at exercise for qualifying cos | 3 years holding | 27.5% for 75% of proceeds | 25% taxed as income | Companies <10 years, < EUR40M turnover, <100 employees | None | Limited to employees of qualifying startups and SMEs, generally excluding board members. | |
Belgium | Taxed at 18% at grant if accepted within 60 days; no additional tax on | |||||||
gains if shares held 2 years post-exercise. | 18% tax at grant | 2 years post-exercise | Not available | Higher rate if not accepted within 60 days | Not available | Proposed amendments to defer taxable events to sale, but currently no | ||
formal additional schemes beyond 18% tax option at grant. | Available to employees; stock options typically taxed upon acceptance. | |||||||
Czech Republic | Deferred tax until triggering event such as sale, termination, liquidation, or 10 years from acquisition for all companies. | Deferred taxation | Triggering event | Adjusted income if share value decreases | Retroactive tax impact on prior grants if exercised post-2024 | All company sizes | None | Available to employees and contractors, with broad company |
eligibility. | ||||||||
Denmark | Tax-free if yearly value <20% of salary and held for 3 years; gains | |||||||
taxed at flat capital gains rate on sale. | No tax at exercise for qualifying cos | 3 years | Flat capital gains rate | Taxed as employment income if conditions not met | Max grant value: 20% of annual salary | None | Primarily for employees; limited scope for board members or | |
contractors under strict conditions. | ||||||||
Estonia | No tax at exercise if held for 3 years, gains taxed at 20% on sale. | No tax at exercise if held >3 years. | 3 years | 20% personal income | Taxed as employment income if exercised <3 years unless exempted | No cap on options or company size | None | Open to employees; also accessible for contractors, with flexibility for various company structures. |
Finland | Stock options taxed as income at exercise and as gains at sale. | Taxed as income at exercise | Not available | Not available | Not available | Not available | None | Open to employees and some contractors, subject to standard income tax. |
France | BSPCE scheme: no tax at grant/exercise for companies <15 years old, | |||||||
<250 employees, <‚Ǩ50M turnover. Gains taxed at flat rate | Tax-free at grant/exercise | 3 years | Flat rate on gains | Not available | Young, small companies | AGA (Attributions Gratuites d’Actions): Allows companies to grant free shares with reduced social taxes if held for 2 years. Designed for both SMEs and larger companies; taxed at a lower rate if conditions met. | Open to employees in eligible companies under BSPCE scheme; | |
contractors are generally excluded. | ||||||||
Germany | Deferred tax for SMEs and startups under €100M revenue and <1,000 | |||||||
employees, with capital gains tax if held >1 year. | No tax at exercise for qualifying SMEs | 1 year | Capital gains tax (flat rate) | Taxed at exercise if non-qualifying company | Limited to qualifying startups and SMEs | None | Limited to employees in qualifying SMEs and startups; not | |
available for contractors or board members. | ||||||||
Greece | No personal income tax at exercise if held for 2 years (3 years for | |||||||
startups); gains taxed at 15% on sale, 5% for startups. | No tax at exercise if held >2 years | 2 years (3 years for startups) | 15% (5% for startups) | Taxed as employment income if exercised early | Beneficiaries must own <0.5% of company | None | Eligible for employees only, with specific limitations on | |
shareholding (must not hold >0.5%). | ||||||||
Ireland | Deferred tax until shares sold if held for 1 year. | No tax at exercise if held >1 year. | 1 year | Capital gains tax (rate varies) | Not taxed as employment income if held >1 year | EUR100k per year or EUR300k total per individual | KEEP (Key Employee Engagement Programme): Allows qualifying companies | |
with <250 employees and <EUR50M turnover to defer tax until sale if | ||||||||
shares held for 1 year. Extended until 2025 as a key support for SMEs. | Primarily aimed at employees, with restricted access for | |||||||
contractors and board members. | ||||||||
Italy | Tax-exempt at exercise for Innovative Startups and SMEs; taxed at flat | |||||||
rate on sale. | No tax at exercise for qualifying cos | Varies | Flat rate at sale | Taxed as employment income at progressive rates if non-qualifying company | Only for Innovative Startups and SMEs | None | Restricted to employees in qualifying Innovative Startups and | |
SMEs. | ||||||||
Latvia | Deferred tax until sale if options held for at least 12 months. | No tax at exercise if held >12 months. | 12 months | 20% capital gains | Taxed as employment income if exercised <12 months | No cap on stock options or company size | None | Open to employees without specific restrictions; contractors and board members are also eligible. |
Lithuania | No tax at exercise if held for 3 years; gains taxed at flat rate on sale. | No tax at exercise if held >3 years. | 3 years | Flat rate on gains | Taxed as employment income if exercised early | No cap on options or company size | None | Open to employees without additional restrictions; contractors may |
be included. | ||||||||
Netherlands | Employees can defer tax to when shares become tradable or 5 years after | |||||||
exercise, taxed at income tax rates. | Deferred income tax | 5 years or until shares tradable | Incremental income tax | Deferred tax requires employee choice; income/capital gains applied based | ||||
on timing. | State approval required for all stock option plans | No other formal schemes, though recent updates reflect a movement toward | ||||||
addressing tax deferral needs. | Primarily available to employees; state approval may impose additional requirements. | |||||||
Norway | Startup scheme: tax deferred to sale if the company is <10 years old, | |||||||
<50 employees, <NOK 80 million. | No tax at exercise for startups | Not available (specific to startups) | Flat rate on capital gains | Taxed as income for other companies | Startups only with strict conditions | None | Restricted to employees in small qualifying startups, with strict limitations on company scope. | |
Poland | No personal income tax at exercise if held for 2 years; gains taxed at a | |||||||
flat rate on sale. | No tax at exercise if held >2 years. | 2 years | Flat rate on gains | Available only for joint-stock SMEs and startups | Only for certain joint-stock and simple JSC SMEs | None | Primarily for employees, but also includes contractors and board | |
members if they hold <5% of shares. | ||||||||
Portugal | Deferred tax until sale if held for 2 years, gains taxed at 50% of value | |||||||
at 28%. | No tax at exercise if held >2 years. | 2 years | Effective 14% on gains | Treated as employment income if exercised <2 years | Startups and SMEs with <250 employees, <EUR50M | None | Available for employees only, typically within startups and SMEs as per criteria. | |
Spain | Startup scheme: employees receive up to EUR50,000/year in stock options tax-free if held for 3 years; taxed on sale at scaling rate. | No tax at exercise if held >3 years | 3 years | Scaling rate | Taxed as employment income if sold <3 years | Certified Emerging Companies, with <5 years old, <EUR10M turnover | None | Open to employees in Emerging Companies; must meet specific |
certification requirements. | ||||||||
Sweden | Tax-free exercise if held for 3 years; gains taxed at flat rate on sale | |||||||
for companies with <150 employees, <SEK 280 million. | No tax at exercise if held >3 years | 3 years | Flat rate on sale | Taxed as income if conditions not met | Limited to companies with <150 employees, <EUR25M | None | Open to employees in qualifying SMEs with restrictions on the | |
company size. | ||||||||
Switzerland | Stock options are subject to income tax at the point of exercise. | Taxed as income at exercise | Not available | Not available | Not available | Not available | None | Available to employees; contractors and board members typically included under general taxation. |
United Kingdom | EMI (Enterprise Management Incentive): No tax on grant/exercise if shares | |||||||
held >2 years; capital gains tax on sale. | No tax at exercise for EMI scheme | 2 years | Capital gains tax | Taxed as income if conditions not met | SMEs with <250 employees, <£30M in assets | CSOP (Company Share Option Plan): Tax-free on grant/exercise for options | ||
up to £60,000; capital gains tax at sale. SIP (Share Incentive Plan): Up to | ||||||||
£3,600 free shares per year tax-free if held for 5 years; CGT may apply at | ||||||||
sale. SAYE (Save As You Earn): Employees save up to £500/month over 3-5 years to buy shares tax-free at exercise; capital gains tax at sale. | EMI scheme limited to employees working >25 hours/week or |
75% of their time; excludes contractors and most board members. |