Malta launches Tax Treatment of Highly Skilled Individuals Rules, offering a 15% flat tax on qualifying expatriate income and extending benefits across finance, STEM, aviation, and other key sectors.
Malta has issued Legal Notice 20 of 2026, introducing the Tax Treatment of Highly Skilled Individuals Rules, 2026, which consolidate and expand the country’s preferential tax regime for expatriates in selected senior and specialist roles.
The framework establishes a specialised tax treatment for professionals employed in designated “eligible offices” in Malta, offering a reduced flat tax rate aimed at attracting qualified individuals to key sectors, including financial services, gaming, aviation, and STEM-related industries.
To qualify, individuals must meet several eligibility conditions. They must earn a minimum annual income of EUR 65,000 from a qualifying contract of employment, excluding fringe benefits. This income threshold increases by EUR 10,000 every five years. Applicants must also hold relevant professional qualifications, evidenced by a degree requiring at least three years of study, or alternatively demonstrate at least five years of relevant professional experience.
Additional requirements include being non-domiciled in Malta, holding a valid travel document, and maintaining private medical insurance covering both the individual and their dependents. Beneficiaries must perform the duties of an eligible office and be engaged as employees under Maltese law.
Under the rules, qualifying income is subject to a flat tax rate of 15%, with no entitlement to further reliefs, credits, or deductions. The reduced rate applies to emoluments of up to EUR 7 million, with any income exceeding this cap taxed at standard rates. The tax benefit applies for an initial period of five years and may be extended twice for additional five-year periods, subject to continued compliance. However, no benefits apply to income earned after 31 December 2040.
The rules apply to a defined list of senior and specialist roles regulated by competent authorities, including the Malta Financial Services Authority, the Malta Gaming Authority, and Malta Enterprise. Eligible offices include C-suite positions such as chief executive, financial, operating, technology, and risk officers, as well as roles in investment management, aviation, maritime, STEM fields, and specialised healthcare services.
Applications must be submitted to the relevant competent authority between 1 January 2026 and 31 December 2035. Authorities are generally required to issue a determination within 90 days.
The legal notice also provides for transitional arrangements. Individuals benefiting from previous schemes, including the Highly Qualified Persons Rules or the Qualifying Employment in Aviation Rules, as at 31 December 2025 may transition to the new regime by submitting an application by the end of 2028. No new determinations will be issued under the former schemes after 2025.
The new rules are applicable from 1 January 2026.
