Global Residence Programme in Malta

The Global Residence Programme in Malta offers internationally mobile high-net-worth individuals a structured and reputable framework through which to acquire a special tax status and establish tax residence in an EU Member State while maintaining global flexibility. By combining remittance-based taxation, predictable residence rules, and access to Malta’s extensive treaty network, the GRP remains a relevant planning tool for executives, entrepreneurs, and internationally mobile families seeking long-term certainty in an increasingly complex international tax environment.

Key Legal Issues

• The Global Residence Programme (GRP) provides a special tax status for eligible non-EU citizens.
• Beneficiaries are taxed in Malta on a remittance basis, subject to a statutory minimum annual tax.
• Eligibility requires qualifying residential property in Malta and evidence of financial self-sufficiency.
• The GRP operates within Malta’s wider residence and personal taxation framework.

What Is the Global Residence Programme in Malta?

The Global Residence Programme is a route that results in the issuance of a special tax status and a residence permit to qualifying individuals who establish residence in Malta while remaining internationally mobile. It is grounded in Maltese tax legislation and administered by the Maltese tax authorities, with a primary focus on determining tax status rather than facilitating permanent relocation.

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Unlike standard residence routes, the GRP allows beneficiaries to be taxed in Malta on a remittance basis. Under this framework, foreign-source income is taxable only to the extent that it is remitted to Malta, while foreign-source capital gains remain outside the Maltese tax net even if remitted. Conceptually, the programme is similar to a res, non-dom framework, while applying the tax rates applicable to special tax status beneficiaries - namely, a flat rate of 15% on foreign-source income remitted to Malta and 35% on locally derived income - rather than the standard progressive resident tax rates (0–35%, in bands). Notwithstanding this, it remains a distinct statutory legislation with its own eligibility criteria and compliance requirements.

Who Is the Global Residence Programme Designed For?

The Global Residence Programme is designed for individuals whose personal, professional, or financial lives span multiple jurisdictions and who require a stable European tax residence base without consolidating all activities in a single country. In practice, it is frequently used by senior corporate executives, entrepreneurs, founders, and high-net-worth individuals with diversified international income streams.

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The programme is also relevant for individuals transitioning between jurisdictions, restructuring their global footprint, or responding to increased taxation or regulatory uncertainty in their home country. It is commonly considered by applicants whose tax and remittance planning involves transferring significant income to Malta.  Families seeking to establish a gradual or partial presence in Europe, rather than an immediate permanent relocation, often find the GRP particularly suitable. It should therefore be viewed as a strategic residence and tax solution rather than a lifestyle-driven relocation programme.

Tax Treatment Under the Global Residence Programme

A central feature of the Global Residence Programme is Malta’s remittance-based system of taxation as applied to GRP beneficiaries and the reduced flat rate of 15% applied on remitted income to Malta.  Foreign-source capital gains fall outside the Maltese tax charge, irrespective of remittance.  Maltese-source income is subject to tax in Malta, irrespective of an individual’s residency status.

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Beneficiaries are subject to a statutory minimum annual tax of €15,000, payable irrespective of actual remittances, which provides predictability for both taxpayers and the Maltese authorities. The framework offers flexibility, but it requires careful planning to ensure that remittance flows, banking arrangements, and income classification are managed correctly. In calculating the tax payable on remitted income, beneficiaries may also be able to avail themselves of double tax treaty relief, where applicable, although such relief is generally available only up to the amount of the minimum annual tax due.

Residence, Property, and Substance Requirements

Eligibility under the Global Residence Programme requires applicants to satisfy specific conditions set out in the regulations, including meeting qualifying property thresholds in Malta and complying with the programme’s substance and administrative requirements.

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Applicants must either purchase qualifying residential property in Malta with a minimum value of €220,000 (or €275,000, depending on the location of the property), or lease qualifying residential property at a minimum annual rent of €9,500 (or €8,750, depending on location). The property must be retained throughout the duration of the special tax status and may not be sublet.

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Applicants must also demonstrate stable and regular financial resources sufficient to support themselves and any dependants without recourse to Maltese social assistance. Comprehensive health insurance covering risks in Malta and across the European Union is mandatory. Beneficiaries must not be domiciled in Malta and must not benefit concurrently from another special tax status.

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While the programme does not impose a rigid minimum physical presence requirement, residence planning must be approached carefully to avoid unintended tax exposure in other jurisdictions. In particular, beneficiaries are typically required, as part of the annual renewal process, to declare that they have not spent more than 183 days in any single country other than Malta, in order to retain their special tax status under the programme. Furthermore, although the GRP itself does not prescribe a minimum stay in Malta, beneficiaries who wish to apply for a Maltese tax residency certificate, or who maintain significant presence or connections in other jurisdictions, should carefully plan their physical and economic presence in Malta to support their overall tax residence position.

Global Residence Programme in the Context of Malta’s Residence Framework

The Global Residence Programme operates alongside other Maltese residence and immigration routes, including ordinary residence, retirement residence programme and permanent residence frameworks. It is not a pathway to citizenship, nor does it in itself create long-term residence rights beyond those linked to the programme’s conditions.

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Its value lies in its function as a planning-oriented residence solution, allowing individuals to anchor their tax residence in Malta while retaining international mobility and benefiting from a special tax rate of 15% on remitted income. As such, it should be assessed independently from citizenship or permanent residence strategies, even where those may be considered at a later stage.

Strategic Planning Considerations Before Applying

Before applying under the Global Residence Programme, individuals should undertake a comprehensive review of their cross-border position. This includes assessing potential exit taxes or ongoing tax exposure in the jurisdiction being left, as well as analysing treaty interaction between Malta and other countries where income arises or personal ties are maintained. Planning should also take into account the timing of the programme’s statutory minimum annual tax payment, as an application submitted late in a calendar year may result in two minimum tax payments (€15,000 each) becoming due within a relatively short period, creating an unintended cash-flow impact.

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Succession planning, family governance, and asset-holding structures should also be reviewed, particularly where trusts, foundations, or operating companies are involved. Banking arrangements, reporting obligations, and the timing and character of remittances to Malta require advance planning to ensure that the programme operates as intended. Where beneficiaries have business or professional activities connected with Malta, it is also important to consider how such activities are appropriately organised from a tax perspective, taking into account the potential treatment of Maltese-source income. The Global Residence Programme is most effective when implemented as part of a coordinated international tax and mobility strategy rather than as a standalone application.

Our Malta Tax Advisors Can Help

Our Malta tax advisors assist internationally mobile individuals and families in assessing whether the Global Residence Programme is appropriate for their circumstances and in structuring their affairs accordingly. In cross-border situations, it is essential to ensure compliance both in the exit jurisdiction and in Malta. We coordinate international tax planning and compliance with professional advisors across jurisdictions to deliver integrated, practical solutions aligned with clients’ long-term objectives. Contact Us.