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Malta’s Tax Treatment of Highly Skilled Individuals Rules provide a statutory framework through which qualifying senior professionals employed in Malta may benefit from a fixed personal income tax rate of 15 % on eligible employment income, subject to defined conditions and safeguards.
Introduced to consolidate and modernise earlier professional-focused incentives, the current rules establish a single, structured framework applicable across selected strategic sectors, including financial services, gaming, aviation, maritime, innovation, and senior corporate functions. Eligibility is determined by reference to the individual’s role, remuneration level, and substantive employment in Malta, rather than nationality or investment considerations.
This publication provides a comprehensive overview of the framework, including eligibility thresholds, qualifying roles, benefits, duration, and key compliance considerations for internationally mobile professionals and employers.
Key Legal Points
- Statutory basis and evolution of Malta’s tax treatment for highly skilled individuals
- Eligibility criteria, qualifying offices, and approved sectors
- Minimum remuneration thresholds and income scope
- Tax benefits, duration, and compliance obligations
- Interaction with Maltese tax residence and international tax standards
Legal Basis and Policy Context
The tax treatment of highly skilled individuals in Malta is governed by subsidiary legislation issued under the Income Tax Act (Chapter 123 of the Laws of Malta). The current framework was introduced through Legal Notice 20 of 2026, replacing and consolidating a number of earlier sector-specific professional tax rules.
The legislative intent is to attract and retain senior talent and specialised expertise that contributes meaningfully to Malta’s economic development, while ensuring alignment with OECD transparency standards, EU law principles, and Malta’s broader tax policy objectives.
Who May Qualify as a Highly Skilled Individual
Eligibility is assessed on a role-based and substance-driven basis. Applicants must be employed in Malta in an eligible office within an approved sector and satisfy the applicable remuneration threshold.
Eligible Offices and Functions
While the precise list is set out in the applicable rules and guidance issued by the Maltese authorities, qualifying roles typically include senior or specialised positions such as:
- Chief executive, chief financial, chief operations, or equivalent C-suite roles
- Senior management and strategic leadership positions
- Heads of technical, regulatory, or specialised operational functions
- Senior professionals exercising control, direction, or decision-making authority
The focus is on seniority, responsibility, and expertise, rather than job title alone.
Approved Sectors
The framework applies to employment within designated economic sectors, reflecting areas of strategic importance to Malta. These include, among others:
- Financial services and regulated financial activities
- Gaming and digital gaming operations
- Aviation and aircraft operations
- Maritime activities and shipping services
- Innovation, technology, and creative industries
- Senior family office, treasury, and back-office operations
Sector eligibility must be confirmed at application stage, and ongoing compliance requires the role to remain within an approved sector throughout the benefit period.
Minimum Remuneration Thresholds
To qualify, the individual must receive annual employment income of not less than the statutory minimum threshold, which is periodically reviewed by the Maltese authorities.
As at the current framework:
- The minimum qualifying remuneration is €75,000 per annum (excluding fringe benefits and non-cash emoluments), adjusted annually in line with cost-of-living mechanisms where applicable.
Only income arising from the qualifying employment may benefit from the preferential tax treatment.
Tax Benefits Available
Eligible individuals benefit from the following core tax features:
- Flat personal income tax rate of 15 % on qualifying employment income
- Income in excess of the applicable upper threshold is exempt from Maltese tax
- No deduction of personal allowances or reliefs against the qualifying income
- Ordinary progressive tax rates apply to any non-qualifying income
This treatment applies solely for Maltese tax purposes and does not, of itself, determine tax residence or treaty entitlement.
Duration of the Tax Treatment
The preferential tax treatment is granted for a limited statutory period, reflecting the policy objective of attracting expertise while preserving long-term tax neutrality.
The benefit may be granted for a maximum period of up to 15 consecutive years, subject to continued eligibility and compliance. Approval is granted for defined periods and may be renewed upon confirmation that conditions continue to be satisfied
Any change in role, employer, or sector must be notified and may require reassessment.
Compliance and Ongoing Obligations
Beneficiaries and employers must adhere to a number of ongoing requirements, including:
- Continued employment in a qualifying office and approved sector
- Maintenance of the minimum remuneration threshold
- Timely tax filings and payment of tax due
- Disclosure of changes affecting eligibility
Failure to meet the statutory conditions may result in withdrawal of the benefit and reassessment under ordinary tax rules.
Interaction with Maltese Tax Residence and International Tax
The tax treatment of highly skilled individuals does not automatically confer Maltese tax residence, nor does it override residence determination under domestic law or applicable double tax treaties.
Individuals benefiting from the framework remain subject to Malta’s international tax obligations, including exchange of information under the Common Reporting Standard (CRS) and other transparency frameworks.
Professional advice is essential where cross-border income, multiple residences, or treaty claims are involved.
Strategic Considerations for Employers and Professionals
For employers, the framework offers a structured and compliant method of attracting senior talent, while for professionals it provides certainty and predictability in personal tax exposure during a Malta-based assignment.
Early planning is critical to ensure that roles, remuneration structures, and contractual arrangements align with the statutory requirements from the outset.
How Our Tax and Private Client Advisors Can Assist
Our tax and private client advisors support internationally mobile professionals and employing entities through eligibility assessments under the highly skilled individuals framework, the structuring of employment packages in line with Maltese tax law, the preparation and submission of applications to the Maltese authorities, ongoing compliance and renewal management, and cross-border tax coordination including residence and treaty considerations.
