With effect from 1st of January 2026, a resident, non-domiciled individual in Malta, earning income from a qualifying contract or eligible office may be eligible for a beneficial tax rate of 15%.
Beneficiaries
Any individual satisfying all the following conditions:
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Receives employment income from an eligible office;
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Is protected by Maltese law as an employee;
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Is in possession of professional qualifications;
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Does not benefit from the Investment Services and Insurance Expatriate Regime;
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Declares emoluments received from the qualifying contact of employment for tax purposes;
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Performs activities of an eligible office;
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Is in receipt of stable and regular resources sufficient to maintain himself and his family without recourse to the social assistance system in Malta;
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Resides in accommodation which satisfies the general health and safety standards in force in Malta;
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Is in possession of a valid travel document;
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Is in possession of private medical health insurance;
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Is not domiciled in Malta.
Conditions
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Employment income is received by a “beneficiary” from an “eligible office”
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Annual emoluments from eligible office amount to at least €65,000
An office is deemed eligible if it falls within a list of positions stipulated in the Rules, and is regulated, licensed or recognised by one of the competent authorities also listed in the Rules.
Transition
The Rules also include transitional provisions applicable to beneficiaries benefitting under the programmes which are being replaced:-
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Highly Qualified Persons Rules;
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Qualifying Employment in Innovation and Creativity (Personal Tax) Rules;
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Qualifying Employment in Aviation (Personal Tax) Rules;
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Qualifying Employment in Maritime Activities and the Servicing of Offshore Oil and Gas Industry Activities (Personal Tax) Rules; and
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Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules.
Extensions may, subject to certain conditions, apply for beneficiaries under the new Rules.
Duration
A beneficiary may benefit under these Rules for a period of 5 years, commencing from the year in which the application is approved, with an option for two further extensions of 5 years each, subject to conditions being satisfied.
The Maltese competent authority commits to issue acceptance or refusal of any application, be it new, or transitory, made under these Rules within 90 days from receipt of the said application.
Way Forward
The harmonisation of the sector-specific programmes into a single set of Rules should enhance consistency and administrative efficiency.
Prospective beneficiaries should carefully assess their eligibility and prepare the required documentation to be submitted within the stipulated deadlines. Our tax team may help you determine your eligibility and guide you through the application process.