Overview
Global equity plans are complex, and administration requires collaboration between various departments, including legal, human resources, payroll, and tax. Plan administrators (and their teams) should be aware of their reporting obligations with respect to international equity awards. Many reports can be submitted by the local entity’s payroll team; however, certain countries require separate standalone submissions.
In Depth
The following reference chart summarizes selected reporting requirements for equity plans with international grantees. This reference – part one of two – highlights year-end reports (i.e., reporting obligations for prior calendar-year 2024 activity) with deadlines through June 30, 2025. It also includes certain quarterly filings. This resource does not include initial registration/exemption applications, reports due upon equity grants, or other standard payroll/tax reports. Additionally, reporting obligations may differ if certain exemptions apply, if the company implements a recharge agreement, or if the local entity is involved with administration of the plan.
Please contact a member of your McDermott team or one of the authors listed below for more information about the listed reporting obligations or for assistance with evaluating which reports may apply to your company based on its current grantee population and plan administration. The team expects to publish part two of this reference chart in April 2025, summarizing applicable reports with deadlines from July through December 2025.
| Country | Report Type | Award Types | Report Description | Frequency | Due Date |
|---|---|---|---|---|---|
| Philippines | Securities |
|
Applies only to plans that have obtained a registration exemption from the Philippines Securities and Exchange Commission | Annually | January 10, 2025, for prior calendar year activity |
| Thailand | Securities |
|
Report option grants and exercises to the Thailand Securities and Exchange Commission | Annually | January 15, 2025, for prior calendar-year activity |
| China | Exchange Control |
|
For State Administration of Foreign Exchange (SAFE)-registered plans, report plan activity via statutory form to the applicable SAFE office | Quarterly1 | January 6, 2025, for prior calendar-quarter activity |
| Vietnam | Exchange Control |
|
Report aggregate share value to the State Bank of Vietnam | Monthly2 | January 12, 2025, for prior month activity |
| Saudi Arabia | Securities |
|
Report plan activity via online portal or email inbox to Capital Markets Authority | Quarterly | As soon as administratively feasible following the end of Q4 2024 data |
| Malaysia | Tax |
|
For each entity in Malaysia, report option exercises/RSU vesting via Form BT (Appendix C) to the Inland Revenue Board | Annually | February 28, 2025, for prior calendar-year activity |
| France | Tax |
|
For tax-qualified options that are exercised or restricted stock units that vest, distribute statement describing grant activity to employees. A copy must also be provided to the applicable tax office. | Annually | March 1, 2025, for prior calendar-year activity |
| Singapore | Tax |
|
Distribute statement describing tax gains activity to employees via Form IR8A (Appendix A) | Annually | March 1, 2025, for prior calendar-year activity |
| Ireland | Tax |
|
Report option-related activity via Form RSS1 | Annually | March 31, 2025, for prior calendar-year activity |
| Tax |
|
Report all other equity-related activity via Form ESA | Annually | ||
| Japan | Tax |
|
For Japanese affiliates that are 50%+ owned by a non-Japanese company or a Japanese branch of a non-Japanese company, report plan activity | Annually | March 31, 2025, for prior calendar-year activity |
| China | Exchange Control |
|
For SAFE-registered plans, report plan activity via statutory form | Quarterly | April 3, 2025, for prior calendar-quarter activity |
| Singapore | Tax |
|
Submit application form for tax deferral eligibility to Comptroller of Income Tax | Annually | April 15, 2025, for prior calendar-year activity |
| Israel | Tax |
|
Report plan activity via Israel Tax Authority online platform | Annually3 | April 30, 2025, for prior calendar-year activity |
