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Malta currently offers several tax programmes to attract foreign individuals to relocate or retire in Malta, including the Global Residence Programme (“GRP”), The Residence Programme (“TRP”), the Malta Retirement Programme (“MRP”) and the United Nations Pensions Programme (“UNPP”) (collectively “Tax Programmes”).
These Tax Programmes not only grant beneficiaries with an immigration status allowing them to reside in Malta, but also offer tax benefits, most prominently the right to pay a flat tax rate of 15% on foreign-sourced income which is remitted to Malta.
The Individual Tax Programme Rules, 2026 (Legal Notice 195 of 2026) (the “Rules“) consolidate these 4 Tax Programmes into a single framework, taking effect on 1 January 2027. The Rules introduce increased annual tax thresholds and application fees, together with a stricter property threshold.
Categories of Special Tax Status
Under the new Rules, an individual may apply for a special tax status under one of the following categories:
- Global resident status
- EU/EEA/Swiss resident status
- Retired pensioner status
- UN pensioner status
Flat Tax Rate of 15% on Foreign Source Income
The new Rules reflect the same flat tax rate of 15% on income arising outside Malta which is remitted to Malta. Under the current rules, beneficiaries of the TRP and GRP are subject to an annual minimum tax of €15,000 whereas MRP beneficiaries are subject to an annual minimum tax of €7,500 (plus an additional €500 per dependent). Beneficiaries under the UNPP are subject to a minimum tax of €10,000 (plus an additional €5,000 where both spouses receive a UN pension). Under the new Rules, the minimum annual tax payments have been increased as follows:
- for those granted global resident or EU/EEA/Swiss resident status: €35,000 per year
- for those granted retired pensioner status: €15,000 per year
- for those granted UN pensioner status: €20,000 per year
The minimum tax is payable in full for both the year in which the status is granted and the year in which it ceases. Beneficiaries must also adhere to certain compliance obligations, such as the filing of an annual tax return.
Whilst foreign-sourced income is subject to tax at 15% if remitted to Malta, under the Rules any income sourced in Malta is subject to tax at 35%.
Property Requirements
Beneficiaries must maintain a qualifying property in Malta or Gozo, occupied as their primary residence. A qualifying owned property is one purchased for a consideration of not less than €700,000, while a qualifying rented property is one leased at not less than €14,000 per year.
The thresholds in the new Rules are higher than those in the current Tax Programmes, reflecting the sustained growth of the Maltese property market and the rise in both purchase prices and rental values. This increase aligns the eligibility criteria with current market conditions, ensuring the investment requirements remain consistent with prevailing property values.
Persons currently benefiting under the existing Tax Programmes who already own a property in Malta or Gozo of a lesser value than that indicated in the new Rules may still be able to qualify. The Commissioner for Tax and Customs is expected to issue guidelines providing further clarity on the new Rules, and it is envisaged that this matter will be addressed.
Status Duration, Fees, and Renewal
Whereas the Tax Programmes currently in place contemplate application fees ranging between €2,500 and €6,000, the new Rules cater for a common, non-refundable administrative fee of €8,500 payable upon application. Special tax status is granted for an initial term of 5 years. Beneficiaries may apply to renew their status for further 5-year periods, subject to a non-refundable renewal fee of €2,500, which renewal shall not be unreasonably withheld by the Commissioner for Tax and Customs.
Any special tax status granted under the current Tax Programmes before or up to 31st December 2026, including applications received up to that date shall continue to apply until 31st December 2031.
Concluding Remarks
Whilst the consolidation of the Tax Programmes into one framework simplifies administration and enhances consistency, it comes at the cost of substantially higher financial thresholds and more stringent qualifying criteria. Nevertheless, these changes reflect a clear policy shift towards a more selective approach to special tax status in Malta.
A smaller pool of high-value individuals who make a larger investment in the property market, meet meaningful tax thresholds, and make a greater contribution to the Maltese economy, is a welcome change marking long-term economic value. Higher entry requirements also boost Malta’s reputation, positioning it alongside other jurisdictions that recognise the quality of applicants rather than quantity.
This article was co-authored with Alessia Bonanno.
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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