Malta: Income Tax

They provide a single special tax status framework covering the ground of four instruments currently in force: the Global Residence Programme, The Residence Programme, the Malta Retirement Programme and the United Nations Pensions Programme (together, the existing programmes).

Malta is consolidating its four existing tax programmes into a unified Individual Tax Programme framework, effective January 2027. The new rules introduce significantly higher annual tax thresholds, increased property requirements, and stricter application fees while maintaining the attractive 15% flat tax rate on foreign-sourced income remitted to Malta.

Malta's Global Residence Programme (GRP) will be replaced by a new Individual Tax Programme from January 2027, introducing substantially higher entry requirements including increased minimum tax obligations and stricter property thresholds. Eligible applicants who submit applications before December 31, 2026 can secure grandfathered status under the current, more favorable GRP terms until 2031, potentially saving significant costs on application fees, property requirements, and annual tax minimums.

Malta's citizenship and taxation systems operate independently, with tax obligations determined by residence and domicile rather than nationality. The Malta Citizenship by Merit programme allows individuals to acquire citizenship while benefiting from the country's non-domiciled tax regime, which taxes only Malta-sourced income and foreign income remitted to Malta.

Income Tax Consolidation has been available in Malta since its introduction through Legal Notice 110 of 2019, being the Consolidated Group (Income Tax) Rules, 2019.

Malta's remittance basis of taxation offers favorable treatment for individuals who are resident but not domiciled in Malta, taxing foreign-source income only when received in Malta while exempting foreign capital gains entirely.

For decades, US businesses viewed tax treaties primarily as technical instruments and mechanisms to reduce withholding tax or avoid double taxation on cross-border income.

Malta has introduced a special tax regime for senior employees of family offices, back offices and treasury management operations, which offers a reduced flat rate of income tax of 15% on employment income.

The Tax Treatment of Highly Skilled Individuals Rules, 2026 (L.N. 20 of 2026), (hereinafter referred to as the "Rules") which came into force on 1st January 2026...