Revenue eBrief No. 219/25
26 November 2025
Share Schemes Chapter 8 - Restricted Shares
Share Schemes – Chapter 08 (Restricted Shares) has been updated as follows:
- Paragraph 1, previously named ‘What are Restricted Shares’ has been renamed 'Introduction.
- Paragraph 8.2 has been updated to provide clarification that;
- the conditionality of restricted shares applies both at the time of acquisition and during the whole length of the specified period, and
- Revenue approval is required in respect of restricted shares to be held in any other arrangement that is not a trust.
- Paragraph 8.6 has been updated to provide clarity that a disposal or transfer of shares before the end of the specified period, in any circumstances not specifically covered in section 128D(3)(c) TCA 1997, may result in the shares no longer being restricted shares for the purpose of section 128D TCA 1997.
- Paragraph 8.9 has also been deleted and its content inserted as paragraph 8.4.1.