In January 2026, the Government of Malta published Legal Notice 20 of 2026, officially titled the Tax Treatment of Highly Skilled Individuals Rules. Effective from 1 January 2026, this new regime consolidates multiple legacy tax incentive programmes into a streamlined, unified framework aimed at attracting and retaining highly skilled expatriates and specialised professionals.
The new rules replace previous sector-specific schemes — including the Highly Qualified Persons Rules and other specialised tax regimes for innovation, aviation, maritime and family office professionals — with a single, coherent 15% flat tax regime on qualifying employment income.
Key Tax Benefits
- Flat 15% tax rate on qualifying employment income earned in Malta.
- This preferential rate applies up to a €7 million annual income cap; income above this is taxed at standard Maltese rates.
- The 15% regime presents a significant advantage compared with Malta’s standard progressive rate structure (which can reach up to 35%).
Eligibility Criteria
To qualify, individuals must satisfy several conditions:
- Be non-domiciled in Malta and employed under a qualifying contract.
- Earn a minimum annual salary of €65,000 (excluding fringe benefits), with this threshold scheduled to increase by €10,000 every five years.
- Hold professional qualifications or at least five years of relevant experience.
- Maintain stable financial resources, appropriate Malta accommodation, a valid travel document, and private medical insurance.
- Work in an eligible role — typically senior or specialised positions regulated or recognised by Maltese authorities (e.g., MFSA, MGA, Transport Malta, Malta Enterprise, and the Chief Medical Officer).
Duration and Extensions
Once approved, beneficiaries enjoy the 15% tax rate for an initial five-year period. They may apply for two further five-year extensions (i.e. up to 15 years total), offering long-term stability for both employees and employers.
Transition for Existing Beneficiaries
Individuals already benefiting from older tax incentive programmes as of 31 December 2025 can apply to transition into the new regime, subject to meeting the updated eligibility conditions and application deadlines.
Strategic Impact
By consolidating multiple incentive schemes, Malta’s Highly Skilled Individuals Rules simplify compliance, reduce administrative complexity and enhance the country’s competitiveness in the global talent market. The unified framework creates clarity for employers looking to attract senior professionals across sectors such as finance, technology, healthcare, aviation, gaming and maritime services.
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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