Taxation for Individuals

Novolegal provides tax planning services through the provision of legal advice in relation to Maltese tax law with regard to income tax, estate planning, real estate transactions as well as guidance with regard to numerous tax incentives and programmes geared towards high net-worth individuals.

Share this practice

Global Residence Programme

The Global Residence Programme (‘GRP’) grants high net worth non-EU, non-EEA and non-Swiss nationals and their family members a special tax status in Malta. Beneficiaries eligible for the programme are charged a flat rate of 15% on all income which arises outside of Malta and is remitted to Malta subject to a minimum tax payment of €15,000, while no tax is charged on income arising outside Malta which is not remitted to Malta. A flat rate of 35% is charged on all incoming arising in Malta. Upon obtainment of a special tax status under the GRP the beneficiary is eligible to apply for a Maltese Residence Card allowing the non-EU/EEA/Swiss national travel throughout the Schengen Zone visa free subject to Schengen Regulations. Prospective applicants must satisfy a number of criteria to apply.

More information on the GRP may be accessed here.

Residence Programme

The Residence Programme (‘TRP’) allows EU, EEA and Swiss nationals and their family members who are not permanent residents of Malta to take up residence in Malta and benefit from a special tax status. Beneficiaries are charged a flat rate of 15% on all income which arises outside of Malta and is remitted to Malta subject to a minimum tax payment of €15,000, while no tax is charged on income arising outside Malta which is not remitted to Malta. A flat rate of 35% is charged on all incoming arising in Malta. Prospective applicants must satisfy a number of criteria to apply. 

More information on the TRP may be accessed here.

Retirement Programme

The Malta Retirement Programme (‘MRP’) grants unemployed EU, EEA and Swiss nationals who are in receipt of a pension as their regular source of income special tax status. Such pension must be received in Malta and must constitute at least 75% of the beneficiary’s chargeable income. A pension may include remuneration of past employment, as lifetime or temporary annuities, as well as income from an occupational retirement scheme, a personal overseas retirement plan and insurance policies. Beneficiaries must not find pursue employment in Malta, however, they may hold a non-executive position on the board of a Maltese company or partake in philanthropic or educational activities related to an institution of a public character.

An individual who has been granted special tax status in accordance with these rules shall be subject to tax at a rate of 15% on income arising outside Malta received in Malta subject to a minimum tax payment of €7,500 . A flat rate of 35% is charged on all income arising in Malta.

Prospective applicants must satisfy a number of criteria, including ownership or lease of immovable property in Malta. In the case of ownership, the property must have a value of €220,000 if situated in the South of Malta or in Gozo, or €275,000 if situated elsewhere in Malta. In the case of a lease, the applicant must rent a property for €8,750 per annum in the south of Malta or in Gozo or €9,600 per annum elsewhere in Malta. The applicant must possess sufficient resources to maintain himself and his family members without recourse to Malta’s social security system. Furthermore, the applicant must obtain a sickness insurance policy which covers him/her and all family members.

Highly Qualified Persons Rules

The Highly Qualified Persons Rules are intended to attract highly qualified workers in the financial services, gaming and aviation industries to occupy an ‘eligible office’ and benefit from special tax treatment. An eligible office in these industries includes:

  • Actuarial Professional;
  • Aviation Continuing Airworthiness Manager;
  • Aviation Flight Operations Manager;
  • Aviation Ground Operations Manager;
  • Aviation Training Manager;
  • Chief Executive Officer;
  • Chief Financial Officer;
  • Chief Commercial Officer;
  • Chief Insurance Technical Officer;
  • Chief Investment Officer;
  • Chief Operations Officer (including Aviation Accountable Manager);
  • Chief Risk Officer (including Fraud and Investigations Officer);
  • Chief Technology Officer;
  • Chief Underwriting Officer;
  • Head of Investor Relations;
  • Head of Marketing (including Head of Distribution Channels);
  • Head of Research and Development; (including Search Engine Optimisation and Systems Architecture);
  • Portfolio Manager;
  • Senior Analyst (including Structuring Professional);
  • Senior Trader/Trader;
  • Odds Compiler Specialist.

Beneficiaries must receive a minimum income of €86,938 which is taxed at a flat rate of 15%. Any income exceeding €5,000,000 is exempt from tax. Such tax treatment is applicable for 5 years for EEA and Swiss nationals and for 4 years for third country nationals, which start running from the year when the individual becomes taxable in Malta.

Applicants must meet a number of eligibility requirements. These include having an income subject to income tax in Malta under an employment contract and possession of professional qualifications and a minimum of five years of professional experience. The applicant must also be in receipt of sufficient income to maintain himself and his family members without reliance on Malta’s social security system and be in possession of sickness insurance which covers him/her and family members.

Share this practice