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Through Legal Notice 195 of 2026, Malta introduced significant amendments affecting The Residence Programme (TRP), the Global Residence Programme (GRP) and the Malta Retirement Programme (MRP), effective 1 January 2027. While the preferential 15% tax rate remains unchanged, future applicants will be subject to higher minimum tax obligations, increased property thresholds, revised application fees and a new five-year validity and renewal framework.
Comparison Table: Current Framework vs Framework Effective 1 January 2027
| Requirement | Current Framework | From 1 January 2027 |
|---|---|---|
| TRP/GRP/MRP Tax Rate | 15% | 15% |
| Minimum Annual Tax (TRP/GRP) | €15,000 | €35,000 minimum annual tax |
| Minimum Annual Tax (MRP) | €7,500 + €500 per dependent | €15,000 minimum annual tax |
| Property Purchase Threshold | Minimum €220,000 for property in Gozo or the South of Malta, or €275,000 for property in other parts of Malta | €700,000 |
| Property Rental Threshold | Minimum €8,750 per year for property in Gozo or the South of Malta, or €9,600 per year for property in other parts of Malta | €14,000 per annum |
| Application Fee | €6,000 (GRP/TRP) €2,500 (MRP) |
€8,500 |
| Validity of Special Tax Status | Ongoing, subject to compliance | 5 years renewable |
| Renewal Fee | Not applicable | €2,500 every renewal |
| Transitional Protection | N/A | Until 31 December 2031 for qualifying applicants |
Legal Notice 195 of 2026 – Key Policy Direction
The amendments retain Malta's attractive special tax framework while requiring a stronger economic commitment from beneficiaries through higher tax contributions, increased property commitments and periodic renewals.
The Residence Programme (TRP)/ Global Residence Programme (GRP) The TRP continues to provide eligible EU, EEA and Swiss nationals with access to a preferential 15% tax rate. From 2027, applicants will be subject to a €35,000 minimum annual tax liability, higher qualifying property thresholds and the new five‑year special tax status validity period.
The GRP remains available to qualifying third-country nationals seeking to establish residence in Malta. Although the 15% tax rate remains unchanged, new applicants will face the same enhanced requirements applicable under the TRP.
Malta Retirement Programme (MRP) The MRP remains one of Malta's most attractive residence solutions for qualifying retirees. Whilst the preferential 15% rate remains intact, beneficiaries will now be subject to a minimum annual tax liability of €15,000 together with the revised property criteria.
Special Tax Status Validity and Renewal Whereas the Commissioner confirms that an applicant qualifies under the relevant rules, a written decision granting special tax status will be issued. The status will remain valid for five years unless withdrawn because eligibility conditions are no longer satisfied.
After the initial period, beneficiaries may renew for further five‑year periods by submitting the prescribed application form, providing any supporting documentation requested and paying a non-refundable administrative fee of €2,500. The Commissioner should not refuse a renewal request without reasonable justification.
Grandfathering Provisions Until 31 December 2031
One of the most important elements of the legislation is the grandfathering provision. Any special tax status granted on or before 31 December 2026, as well as any application received by that date, will remain valid until 31 December 2031.
This means that:
- Existing beneficiaries retain protection until 31 December 2031.
- Applications submitted before 31 December 2026 benefit from the transitional provisions even if approval is issued after that date.
- Applications submitted from 1 January 2027 onwards will be subject to the new framework.
Scenario 1 – Existing Beneficiary
A beneficiary approved under the GRP in 2025 will continue to benefit from the transitional arrangements until 31 December 2031, provided all programme conditions continue to be satisfied.
Scenario 2 – Pending Applicant
A complete application submitted prior to 31 December 2026 but approved during 2027 may still fall within the grandfathering provisions because the application was received before the statutory deadline.
Scenario 3 – New Applicant After 1 January 2027
The applicant will be subject to the €35,000 minimum annual tax requirement (TRP/GRP), €700,000 property purchase threshold or €14,000 annual rent, €8,500 application fee and five‑year renewal framework.
What This Means for Applicants
The amendments do not remove the attractiveness of Malta's residence programmes. The preferential 15% tax rate remains in place. However, the overall cost of entry and ongoing participation will increase significantly. Individuals undertaking relocation, retirement or residence planning should carefully evaluate these changes and consider the implications of the transitional provisions available until the end of 2026.
CSB Group Commentary
The amendments introduced through Legal Notice 195 of 2026 represent one of the most significant developments affecting Malta's special tax residence landscape in recent years. The reforms indicate a clear policy direction towards attracting individuals who are prepared to establish a stronger economic and residential connection with Malta.
How CSB Group Can Assist
CSB Group assists private clients, retirees, entrepreneurs and internationally mobile families with eligibility assessments, residence applications, tax residence planning, property-related compliance matters and ongoing maintenance of special tax status.
Conclusion
Whilst retaining the attractive 15% tax rate, the reforms substantially increase the financial commitments associated with obtaining special tax status in Malta. Existing beneficiaries and applicants who submit their applications by 31 December 2026 will benefit from important grandfathering provisions extending until 31 December 2031. Early planning and professional advice remain essential.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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