Malta has introduced the Individual Tax Programme Rules, 2026 under Legal Notice 195 of 2026, establishing four special tax statuses from 1 January 2027 with a 15% tax rate on qualifying foreign income, minimum annual tax requirements and new eligibility and compliance rules for applicants.
Malta has published Legal Notice 195 on 14 July 2026, setting out the Individual Tax Programme Rules, 2026, which establish a new framework for granting special tax status to eligible individuals from 1 January 2027.
The rules introduce four categories of special tax status: Global Resident Status, EU, EEA, Swiss Resident Status, Retired Pensioner Status, and UN Pensioner Status. Individuals approved under one of these categories will generally be subject to a flat 15% tax rate on income arising outside Malta that is received in Malta, while other non-qualifying income will remain taxable at 35%.
For beneficiaries granted UN Pensioner Status, a United Nations pension or widows’/widowers’ benefit received in Malta will be exempt from tax. Other qualifying foreign income received in Malta will continue to be taxed at 15%.
Special tax status categories
The rules set separate eligibility requirements and minimum annual tax obligations for each category.
Global Resident Status is available to qualifying third-country nationals who are not EU, EEA, Swiss or Maltese nationals and are not long-term residents. Beneficiaries must pay a minimum annual tax of EUR 35,000.
EU, EEA, Swiss Resident Status applies to qualifying EU, EEA and Swiss nationals who are neither Maltese nationals nor permanent residents of Malta. The minimum annual tax is also EUR 35,000.
Retired Pensioner Status is available to qualifying individuals who are not Maltese nationals, long-term residents or permanent residents of Malta and who receive a qualifying pension in Malta representing at least 75% of their total chargeable income. The minimum annual tax is EUR 15,000.
UN Pensioner Status applies to qualifying individuals who are not Maltese nationals, long-term residents or permanent residents of Malta and who receive a United Nations pension or widows’/widowers’ benefit, with at least 40% of that pension or benefit received in Malta. The minimum annual tax is EUR 20,000.
Application and eligibility
Applications must be submitted through an authorised registered mandatary, such as a warranted advocate, notary or accountant, who will also handle official correspondence with the authorities.
A non-refundable administrative fee of EUR 8,500 is payable when applying. Approved status is granted for an initial five-year period and may be renewed for successive five-year terms on payment of a EUR 2,500 renewal fee.
Applicants must satisfy several general conditions. They must not benefit from another residency programme, must own or rent a qualifying primary residence in Malta or Gozo, possess stable and regular financial resources, hold sickness insurance covering risks throughout the European Union, and have a valid travel document.
Applicants must also not be domiciled in Malta or intend to establish domicile there within five years of the application, be able to communicate adequately in Maltese or English, and satisfy the “fit and proper person” requirement.
To qualify through property ownership, applicants must own a residence with a minimum value of EUR 700,000 or lease a residence with an annual rent of at least EUR 14,000.
Loss of status
The rules also specify circumstances under which special tax status will cease immediately. These include becoming a Maltese national or a long-term or permanent resident, no longer holding qualifying property, spending more than 183 days in another jurisdiction during a calendar year, failing to pay the required minimum tax or submit required tax returns, or no longer being represented by an authorised registered mandatary.
Transitional arrangements
The Individual Tax Programme Rules, 2026 will take effect on 1 January 2027. Special tax status granted, or applications received, on or before 31 December 2026 will continue under their existing terms until 31 December 2031.
