Malta Introduces New Individual Tax Programme Rules Effective from 1 January 2027
The Malta Tax and Customs Administration (MTCA) has published Legal Notice 195 of 2026, introducing a new framework governing Malta’s individual tax programmes under the Income Tax Act (Cap. 123).
The new rules will apply to new applications submitted from 1 January 2027, replacing the existing special tax status programmes with a modernised framework while maintaining many of the tax benefits that have made Malta an attractive destination for internationally mobile individuals.
Existing Programmes to be Renamed
The current special tax status programmes will be replaced with the following categories:
- Global Resident Status (Third-Country Nationals)
- EU/EEA/Swiss Resident Status
- Retired Pensioner Status
- UN Pensioner Status
Individuals already benefiting from the existing Global Residence Programme (GRP), The Residence Programme (TRP), Malta Retirement Programme (MRP), or UN Pension Programme (UNPP) may continue under their current status until 2031.
Tax Benefits Remain Unchanged
One of the key attractions of Malta’s special tax status programmes remains in place.
Eligible individuals will continue to benefit from:
- A 15% flat tax rate on foreign-source income remitted to Malta.
- The possibility of claiming double taxation relief, where applicable and subject to the relevant treaty provisions.
Annual Minimum Tax Liability
The minimum annual tax payable will depend on the applicable programme:
Programme | Annual Minimum Tax |
Global Resident Status (Third-Country Nationals) | €35,000 |
EU/EEA/Swiss Resident Status | €35,000 |
Retired Pensioner Status | €15,000 |
UN Pensioner Status | €20,000 |
Registration Fees
Applications under the new framework will be subject to the following administrative fees:
- Initial application: €8,500 (non-refundable)
- Status validity: 5 years
- Renewal: Additional 5-year period upon payment of a €2,500 registration fee
Minimum Property Requirements
Applicants must maintain a qualifying property in Malta as their principal residence.
The minimum qualifying thresholds are:
- Purchased property: Minimum value of €700,000
- Leased property: Minimum annual rent of €14,000
Ongoing Compliance Requirements
Beneficiaries will be required to continue satisfying several ongoing obligations, including:
- Maintaining a qualifying property as their principal residence.
- Maintaining valid travel documentation.
Residency Conditions
Individuals benefiting from the programme must also comply with residency limitations, including:
- Not spending more than 183 days in any other jurisdiction during a calendar year.
- Not acquiring long-term or permanent resident status in another jurisdiction.
Additional Eligibility Requirements
Applicants must also demonstrate that they:
- Have stable and regular financial resources sufficient to support themselves and their dependants.
- Hold valid travel documentation.
- Maintain comprehensive health insurance covering themselves and their dependants.
Exclusions
An individual cannot benefit from these rules if they already benefit under another special tax status or residence programme.
Preparing for the New Framework
Although the new rules only apply to new applications from 1 January 2027, prospective applicants should begin evaluating their eligibility in advance, particularly where property acquisition, tax planning, or relocation arrangements are involved.
At Tri-Mer, we assist international individuals throughout the application process, including eligibility assessments, tax planning, residency applications, and ongoing compliance.
Should you wish to understand how the new Individual Tax Programme Rules may apply to your circumstances, our advisory team would be pleased to assist.
Marouska Farrugia
Private Client & Residency Manager
Ian Mercieca
Partner
