Malta’s new Individual Tax Program comes into force on January 1, 2027, keeping the 15% rate that foreign residents pay on overseas income they bring into the country. The government published the rules in Legal Notice 195 of 2026 on July 14.
Non-EU applicants will face a €35,000 minimum annual tax, up from €15,000 under the current Global Residence Program (GRP). Almost every other entry cost rises too.
Four categories
Applicants fall into four categories of special tax status. Third-country nationals who are not long-term residents apply for global resident status. Nationals of the EU, the European Economic Area (EEA), and Switzerland have their own category, provided they are neither Maltese nationals nor permanent residents of Malta.
Retired pensioners and recipients of a United Nations pension make up the other two. A retired pensioner must receive all of his pension in Malta, and it must account for at least 75% of his chargeable income. UN pensioners must bring at least 40% of their UN pension into the country.
PwC, BDO, and several Maltese law firms describe the rules as the successor to four existing programs. These are the GRP, The Residence Program, the Malta Retirement Program, and the United Nations Pensions Program.
The legal notice itself names none of the four. Malta’s tax authority, the Malta Tax and Customs Administration (MTCA), still lists all of them on its website.
Tax treatment
A beneficiary pays 15% on foreign income that he, his spouse, and his minor children receive in Malta, with relief for tax paid abroad. Malta charges 35% on any other income of theirs that it taxes. Foreign income left abroad stays outside the Maltese net, under the remittance basis for residents not domiciled in Malta.
Applicants must show they are not domiciled in Malta. They must also have no intention of establishing domicile there within five years of applying.
Higher thresholds
Global residents and EU/EEA/Swiss residents will owe at least €35,000 (approximately US$40,000) a year. The retired pensioner minimum stands at €15,000, and UN pensioners owe at least €20,000 on income other than their UN pension, which remains exempt.
How much the higher floor bites depends on the applicant, says Ryan Darmanin, Chief Operations Officer at Latitude Group. An applicant “already paying more than €35,000 on foreign income brought into Malta may see little change to that tax bill.” By contrast, someone “who would have paid the €15,000 minimum under the current rules faces a substantial increase.”
Property thresholds move further still. A qualifying purchase must cost at least €700,000 (approximately US$801,000), and a qualifying lease at least €14,000 a year, anywhere in Malta or Gozo. Under the GRP, those figures stand at €275,000 and €9,600, dropping to €220,000 and €8,750 in southern Malta and Gozo.
Applicants will pay an €8,500 fee, up from the GRP’s €6,000, or €5,500 for property in the south. Status now runs for five years at a time. Each renewal costs €2,500.
Beneficiaries who bought below the new threshold get some room. Property that a beneficiary purchased for less than €700,000 before the rules take effect can still qualify, on terms the Commissioner for Tax and Customs will set in guidelines.
Transitional window
Anyone granted status by December 31, 2026, keeps it until December 31, 2031. The same protection covers “any applications for the granting of such status received up to the same date.”
That wording settles a point on which adviser summaries have diverged. Some refer only to status granted by the deadline. Under the text, receipt of the application is what counts.
James Muscat Azzopardi, Managing Partner at Muscat Azzopardi & Associates, acts for GRP applicants as a registered mandatary. He says anyone interested should “apply before the end of December, to lock in a five-year period with the 15k minimum tax applied.”
Nothing in the rules says what happens to those beneficiaries after 2031. Several Maltese advisory firms expect them to move onto the new framework at renewal.
Darmanin calls the protection through 2031 “welcome” and says “it gives families time to plan.” What would help now, in his view, is “clear guidance on subsequent renewals and how properties bought under the previous thresholds will be treated.”
Ongoing obligations
Each year’s minimum tax falls due by April 30 and is not refundable. Beneficiaries owe the full amount in the year status begins and again in the year it ends.
Status ends if the beneficiary lets or sublets the qualifying property or spends more than 183 days in any other jurisdiction in a calendar year. Becoming a Maltese national, or a long-term or permanent resident of Malta, also ends it. So does losing private medical insurance.
Every application, filing, and notification must go through an authorized registered mandatary, meaning a Malta-warranted advocate, legal procurator, notary, or accountant registered with the Commissioner. A mandatary who misses the annual check on clients’ long-term residence faces a €10,000 penalty. After more than two failures to carry out his duties, he loses his registration.
Beneficiaries carry penalties of their own. Failing to report a change in dependents within four weeks costs €5,000.
Relative cost
At €35,000, Malta’s floor still sits well below the six-figure annual sums that Italy and Greece charge under their flat-tax regimes for new residents. Muscat Azzopardi calls the new minimum “extremely reasonable for European residency.”
In his view, the GRP “had been long overdue an update and is still a very attractive option.” He sees the regime as best suited to “an internationally mobile investor or business owner whose income is mainly foreign-sourced.”
Darmanin cautions against reading too much into the Italy and Greece comparison. “Comparing a minimum tax with a fixed annual charge elsewhere does not give the full picture,” he says. A fair comparison weighs “what a family would actually pay and how much foreign income it intends to bring into Malta.”
The Malta Permanent Residence Program (MPRP) sits outside the new rules. It grants residence and, on its own, no tax residency.
Wider trend
Rafael Cintron, CEO at Wealthy Expat, sees the changes as part of a broader pattern. “When it comes to tax, residency, and especially citizenship by investment, everything gets harder and more expensive over time,” he says. “Or disappears entirely.”
Cyprus “might be the next one,” he suggests, “especially now that they prepare to join Schengen,” with “stricter taxes, higher thresholds, more difficult overall.” His advice to clients: “When a program is attractive, clients should jump on the opportunity fast.”
