Senior Employees of Family Offices, Back Offices, and Treasury Management Operations Tax Rules (Legal Notice 250 of 2025), introduced a 15% tax rate for senior employees of specific undertakings with effect from 1 January 2025 – this initiative aims to attract top talent and continue to support a substantial family office sector.
Who can benefit?
Senior professionals who have a qualifying employment contract in an eligible office, including Chief Executive Officers, Heads of Back Office, General Managers, Country Heads, Managing Directors, Chief / Heads of Risk / Compliance Officers, Portfolio Managers, Chief / Heads of Investment Officers, Senior Structuring Professional and Senior Traders, with the below undertakings:
- Single or multifamily offices.
- Undertakings providing back-office services and treasury management operations to family offices.
Eligibility criteria
To qualify, employees should satisfy a number of conditions, including (amongst others):
- Earn a gross basic salary of at least €65,000 per year (i.e. excluding fringe benefits), with this threshold increasing by €10,000 every five years.
- Their first employment in Malta should be in an eligible office. Furthermore, the employees should not have earned any employment income or income from a trade, business, profession or vocation which was chargeable to Maltese income tax before 1 January 2025.
- Have relevant professional qualifications / experience.
- Not be domiciled in Malta.
How does it work?
Qualifying individuals, in possession of a determination issued by the competent authority, may opt to be taxed at a 15% flat tax rate on gross emoluments earned from a qualifying employment contract up to €7m (without the possibility to claim any relief, deduction, reduction, credit or set-off of any kind), from the year in which the determination is issued.
Other income chargeable to Maltese income tax and income from the qualifying contract of employment exceeding €7m is subject to tax at 35%.
The 15% tax rate applies for five consecutive years from the year in which a formal determination is issued by the competent authority, with the option to apply for two further extensions of five years each, up to a maximum of 15 consecutive years. These Rules will cease to apply on 31 December 2040.
Individuals satisfying the criteria, should submit the relevant application form together with the supporting documentation to the competent authority. If approved, the competent authority will issue them with a formal determination confirming that they are beneficiaries in terms of the Rules within the prescribed timeline.
Beneficiaries should continue satisfying the conditions outlined in the Rules on an on-going basis and abide to annual compliance obligations.
Disclaimer
The above does not constitute tax or legal advice and is up to date on the date it was published. Please ensure that you take appropriate advice from tax or legal professionals before making any decisions based on the above.
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