Malta's new individual tax programme: a consolidated framework for relocation to Malta

Effective from 1 January 2027, Malta's new Individual Tax Programme (ITP) introduces a consolidated tax residence framework for individuals seeking to relocate to Malta. The programme brings together a number of existing residence schemes under a single legislative framework and offers eligible applicants the opportunity to obtain special tax status and benefit from a preferential tax regime.

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Key Benefits

Eligible individuals may benefit from:

• Special tax status granted for an initial period of five years, renewable for further five-year periods subject to continued compliance.
• A 15% flat tax rate on foreign-source income remitted to Malta.
• Minimum annual tax liabilities ranging from €15,000 to €35,000, depending on the applicable status category.
• The possibility of including qualifying dependants under the same application.
• The right to reside in Malta and enjoy short-term travel within the Schengen Area (up to 90 days within any 180-day period).

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Who Can Apply?

The programme is designed for foreign individuals establishing Malta as their principal place of residence and provides four categories of special tax status:

• Global Resident Status (non-EU, non-EEA and non-Swiss nationals)
• EU/EEA/Swiss Resident Status (EU, EEA and Swiss nationals)
• Retired Pensioner Status
• UN Pensioner Status

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Main Eligibility Requirements

Applicants must satisfy a number of conditions, including:

• Hold a qualifying residential property in Malta:  
• Purchase value: minimum €700,000
• Annual rental value: minimum €14,000
• Maintain valid health insurance covering risks normally covered for Maltese nationals throughout the European Union.
• Demonstrate sufficient stable and regular financial resources to support themselves and their dependants.
• Hold a valid travel document.
• Be able to communicate adequately in one of Malta's official languages.
• Confirm that they are not domiciled in Malta and do not intend to establish domicile in Malta within five years of the application.

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Tax Treatment

The Individual Tax Programme operates on Malta's remittance basis of taxation, whereby foreign-source income is taxed only when received in Malta.

Under the programme:

• Foreign-source income remitted to Malta is subject to tax at a flat rate of 15%.
• Malta-source income remains taxable at the standard rate of 35%.
• A minimum annual tax liability applies, depending on the relevant status category.

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Transitional Provisions

The Individual Tax Programme will come into force on 1 January 2027. Until 31 December 2026, the existing residence programmes, namely the Global Residence Programme (GRP), Residence Programme (RP), Malta Retirement Programme (MRP) and United Nations Pension Programme (UNPP), will remain in force and any special granted until the end of 2026 will continue to apply until 2031. Thereafter, any renewal of that status will be required to be made under the ITP.

From 1 January 2027, new applicants seeking to benefit from a special tax status in Malta will be required to apply under the Individual Tax Programme, subject to the applicable eligibility criteria and conditions.

This transitional period provides prospective applicants and advisers with an opportunity to assess the most suitable route based on their circumstances before the new consolidated framework becomes fully operative.

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Conclusion

The ITP introduces a more unified approach to Malta's residence-based tax regimes, whilst preserving many of the features that have made Malta an attractive destination for international individuals and families. As the new framework takes shape, understanding the eligibility requirements and long-term implications of each option will be key to making an informed relocation decision.