EU Inc. proposes a harmonised employee stock option regime, often referred to as the EU-ESO. The aim is to remove the "dry income" problem that taxes employees at exercise rather than at sale of shares, and to align treatment across the 27 member states so a cross-border startup can offer a single plan.
The pace of change is uneven. France (BSPCE), Estonia (3-year vesting rule), Portugal (2023 Startup Law), Sweden (qualified employee options), and Spain (€50,000 exemption under the 2022 Startup Law) already have favourable regimes. Germany's Zukunftsfinanzierungsgesetz of 2024 narrowed the gap but did not close it. Several member states still tax options at exercise without deferral.
This topic page tracks each country's official position on the EU-ESO module, its current national regime, any tax authority guidance, and signals from the responsible ministry. Comparison is the unit of analysis: founders care about effective rate and timing across jurisdictions, not abstract policy.