# Malta Merges Its Tax Programmes for New Residents: What the Individual Tax Programme Changes from 2027 > Dr. Werner & Partner - International Law Firm in Malta > URL: https://www.drwerner.com/en/malta-individual-tax-programme-2027/ ## Metadata - **Author:** Dr. Werner & Partners - **Published:** 2026-10-02 - **Topic:** Tax Planning - **Jurisdictions:** Malta - **Reading time:** 17 min --- On 14 July 2026, Malta published the Individual Tax Programme Rules. Legal Notice 195 of 2026 merges four existing special tax regimes into one and comes into force on 1 January 2027. The 15% rate on foreign income remitted to Malta stays as it is. What changes is the cost of entry: the minimum tax rises from EUR 15,000 to EUR 35,000, the property threshold from EUR 275,000 to EUR 700,000, and the regional reductions for Gozo and the south of Malta disappear. That creates a deadline. If your application reaches the Commissioner for Tax and Customs (Malta's tax authority) by 31 December 2026, you can keep the current terms until the end of 2031. ## Key points at a glance - From 1 January 2027, the Individual Tax Programme replaces four regimes for new applications: the Global Residence Programme, The Residence Programme, the Malta Retirement Programme and the United Nations Pensions Programme. - The rate remains 15% on foreign income remitted to Malta. The annual minimum tax rises from EUR 15,000 to EUR 35,000, and for pensioners from EUR 7,500 to EUR 15,000. - The property threshold becomes a single figure: a purchase price of EUR 700,000 or annual rent of EUR 14,000. Until now, depending on location, it ranged from EUR 220,000 to EUR 275,000, or from EUR 8,750 to EUR 9,600. - Applications received by the Commissioner for Tax and Customs by 31 December 2026 continue on the current terms until 31 December 2031. - Whether the higher minimum tax affects you comes down to one figure. Under Global Resident Status and EU, EEA and Swiss Resident Status, the new minimum tax makes no difference once you remit around EUR 233,000 of foreign income. Below that, your effective rate rises above 15%. ## What is the Individual Tax Programme? The Individual Tax Programme is a special tax status for people who move their centre of life to Malta without being domiciled there. Its legal basis is Articles 56(23) and 96 of Malta's Income Tax Act (Cap. 123). The principle is the same as under the previous programmes: income that arises abroad and is remitted to Malta is taxed at a flat 15% instead of the progressive rates of up to 35%. Foreign income that stays abroad is not taxed in Malta. Double Tax Treaties continue to apply, and credit is available for foreign tax. What is new is the consolidation. Until the end of 2026, four programmes with different target groups, fees and thresholds exist side by side. From 2027, there will be a single set of rules with four status categories. For the administration, that means less work. For people moving to Malta, it mainly means higher entry costs, because Malta has used the consolidation to raise the financial requirements. The status is granted for five years and can be renewed on application for further five-year periods. Under the wording of the rules, renewal cannot be refused without good reason. ## The four statuses at a glance ### Global Resident Status For third-country nationals, meaning nationals of countries outside the EU, the EEA and Switzerland. You must be neither a Maltese national nor a long-term resident within the meaning of Maltese law. The minimum tax is EUR 35,000 per year of assessment. Since Brexit, UK nationals are third-country nationals, so this is the status that applies to them. They also need a separate Maltese residence permit (more on this below). ### EU, EEA and Swiss Resident Status The counterpart for nationals of the EU, the EEA and Switzerland. The minimum tax here is also EUR 35,000. Maltese nationals and people with a permanent right of residence in Malta are excluded. For Irish nationals moving to Malta, this is the relevant status. ### Retired Pensioner Status For retirees whose pension makes up at least 75% of their chargeable income and is remitted to Malta in full. The minimum tax is EUR 15,000. It replaces the previous combination of a EUR 7,500 base amount plus EUR 500 for each dependant and each carer. For families with several dependants, this makes the increase somewhat smaller than a straight comparison of the base amounts suggests. We cover everything else a move in retirement involves in our [guide to retiring in Malta](https://www.drwerner.com/en/retiring-to-malta-comprehensive-guide/). ### UN Pensioner Status For recipients of a pension from the United Nations Joint Staff Pension Fund, and for surviving spouses entitled to the Fund's Widow's or Widower's Benefit. At least 40% of this pension must be received in Malta. The UN pension itself remains tax-free in Malta. Other foreign income is taxed at 15%, with a minimum tax of EUR 20,000. A person can hold only one of these statuses at a time. Anyone who already benefits from another Maltese special regime, such as the Highly Qualified Persons Rules, is excluded. ## What actually changes ### Minimum tax - Global Resident and EU, EEA and Swiss Resident: EUR 35,000, up from EUR 15,000 - Retired Pensioner: EUR 15,000, up from EUR 7,500 plus EUR 500 for each dependant and each carer - UN Pensioner: EUR 20,000, up from EUR 10,000, which rose by EUR 5,000 if both spouses received a UN pension The minimum tax is payable in full both in the year the status is granted and in the year it ends. The law makes no provision for a pro rata reduction, and amounts paid are not refundable. Payment is due by 30 April of the year preceding the relevant year of assessment, together with a declaration that all conditions are still met. No declaration is needed in the year the status is granted; if it is clear that the status will only be granted after 30 April, the minimum tax must be paid before it is granted. ### Property - Purchase: a single threshold of EUR 700,000 for Malta and Gozo, instead of EUR 275,000 in Malta and EUR 220,000 in Gozo or the south of Malta - Rent: a single threshold of EUR 14,000 a year, instead of EUR 9,600 in Malta and EUR 8,750 in Gozo or the south The regional tiering disappears entirely. If you could previously rely on the lower thresholds through a property in Gozo or the south of Malta, that advantage is gone. ### Fees - Application fee: a single, non-refundable EUR 8,500. Previously EUR 6,000 under the Global Residence Programme and The Residence Programme (reduced to EUR 5,500 for a property in the south of Malta or Gozo), EUR 2,500 under the Malta Retirement Programme and EUR 4,000 under the United Nations Pensions Programme (reduced to EUR 3,500 depending on location) - Renewal: EUR 2,500 per five-year period Regional tiering disappears from the fees as well. ### Duration Until now, the special status applied indefinitely, as long as the conditions continued to be met. From 2027, it is granted for five years and must be actively renewed. For planning purposes, this is the more far-reaching change: the status now comes up for review every five years. ### What stays the same - The 15% rate on foreign income remitted to Malta - The remittance basis: foreign income that never reaches Malta remains untaxed there - Credit for foreign tax under Double Tax Treaties - Malta-source income is taxed separately at 35% - The obligation to be represented by an Authorised Registered Mandatary (a licensed, registered representative) ## What the change means in figures The increase in the minimum tax looks more dramatic than it turns out to be for some applicants. One simple threshold decides it: the minimum tax only bites if 15% of your remitted foreign income falls below it. With a minimum tax of EUR 35,000, that is the case up to a remitted amount of around EUR 233,000. Above that, you pay more than the minimum tax anyway, and the change passes you by. Three scenarios show the range. An entrepreneur who remits EUR 400,000 of foreign income to Malta pays EUR 60,000 in tax. That is the same before and after the reform, because her regular tax comfortably exceeds the minimum tax in both cases. Her effective rate stays at 15%. What changes for her are mainly the property threshold, the application fee and the fixed term with its renewal fee. An entrepreneur who remits EUR 150,000 pays EUR 22,500 under the old rules: the regular 15%, since that figure is above the old minimum tax of EUR 15,000. Under the new rules, the minimum tax of EUR 35,000 applies. Her effective rate rises to around 23%, an extra EUR 12,500 a year. A retired couple with a pension of EUR 60,000, all of it paid into Malta, pays EUR 9,000 under the old rules, because 15% is more than the minimum tax of EUR 7,500 plus EUR 500 for the wife. Under the new rules, EUR 15,000 is due. Their effective rate jumps to 25%, an extra EUR 6,000 a year. Of the three examples, this is where the effective rate rises most sharply. On top of this come one-off and ongoing costs. In the first year, the application fee and minimum tax will together come to EUR 43,500, plus at least EUR 14,000 in annual rent if you rent. Under the old rules, the same items came to EUR 21,000, plus at least EUR 9,600 in annual rent. Fees for the mandatary, the notary and ongoing tax advice apply in both scenarios. ## The deadline: 31 December 2026 The transitional provision sits in Rule 3(3) and is short. Any status granted by 31 December 2026 continues to apply, and applications received by that date are expressly covered too. Both run until 31 December 2031. What counts, then, is not approval but receipt by the Commissioner for Tax and Customs. If you start the process now and submit your application in time, you can secure five years on the current terms once it is approved. Over that period, the financial difference is considerable. For the entrepreneur remitting EUR 150,000, it comes to EUR 12,500 a year, or EUR 62,500 over five years. The lower property threshold and the lower application fee come on top. The rules are silent on what happens to existing cases after 31 December 2031. The wording says the old status continues until that date, not what follows. The most likely reading is a transfer into the new regime on its terms. So far there is no express provision on this, and no administrative guidance either. If you are planning now, treat the grandfathering as a time-limited advantage. In practice, the deadline comes sooner than the date suggests. A complete application requires a secured property, proof of health insurance, income and source of funds, and an appointed mandatary. If you start in December, you are unlikely to get the documents together in time. ## Conditions that are often underestimated One point applies to everything below: a breach has retrospective effect. The status is lost from the start of the relevant year of assessment, not from the day of the breach, and the whole year is then taxed at the ordinary rates. ### A mandatary is compulsory No application goes ahead without an Authorised Registered Mandatary. Only advocates, legal procurators, notaries and certified public accountants holding a Maltese warrant qualify, along with companies in which at least 75% of the shareholders are such professionals. Your status depends directly on this choice. The mandatary files all applications, declarations and returns. If they miss an annual return, they face an administrative penalty of EUR 10,000; if they fail to provide information requested in the course of supervision on time, the penalty is EUR 500 to EUR 19,250. After more than two failures, they lose their registration, and you lose your status with it. ### The 183-day rule targets your time outside Malta The rules set no minimum stay in Malta. You do lose the status, though, if you spend more than 183 days in a calendar year in another jurisdiction. The wording refers to time spent in a single other jurisdiction; the rules do not provide for adding up all your stays abroad. The administration has yet to confirm this expressly. If you regularly spend the winter in the same place outside Malta, keep count. ### The qualifying property cannot be let You must live in the property as your principal residence, and as your centre of life worldwide. Letting or subletting it ends the status. Only you, your dependants and registered domestic staff who have worked for you for at least two years may live there. Financially independent persons tied to the same matrimonial home may also live there, provided the Commissioner has been informed. If you see Maltese property as an investment, you will need a second one for that purpose. ### Permanent residence ends the tax status If you become a Maltese national, a long-term resident or a holder of a permanent right of residence, you lose the status. That seems contradictory at first, but it follows the logic of the regime: it is aimed at people who are resident in Malta without putting down roots there. If, after several years, you are thinking of making your residence permanent, factor in the tax consequences. Your mandatary must check with you every year as at 31 December and report the result by 30 April. ### Other requirements You must not be domiciled in Malta and, for five years from your application, must not intend to establish a Maltese domicile. You also need health insurance valid throughout the EU for yourself and your dependants, stable and sufficient resources of your own, a valid travel document, adequate command of one of Malta's official languages (Maltese or English) and a successful due diligence check. Changes among your dependants, and any condition you no longer meet, must be reported within four weeks, or you risk an administrative penalty of EUR 5,000. ## A tax status is not a residence permit The Individual Tax Programme governs taxation only. On its own, it gives you no right of residence. Irish nationals derive their right of residence from EU free movement and register in Malta in the usual way. UK nationals, like all third-country nationals, also need a residence permit, which they apply for separately from the tax status. The Malta Permanent Residence Programme is a different matter. It is administered by the Residency Malta Agency and grants permanent residence in return for a contribution, a property and a donation, but it confers no special tax status. Under the wording of the rules, the two routes do not exclude each other, but they are applied for and assessed separately. Work out which route suits your situation before you commit to a property or submit an application. ## An important nuance for property you already own The EUR 700,000 threshold does not apply retrospectively to everyone. The rules contain an exception for property that a beneficiary bought at a lower price on or before the date the new rules come into force. Such property can continue to count as qualifying property. The Commissioner will set out the details in guidelines under Article 96(2) of the Income Tax Act. At the time of writing (early October 2026), these guidelines had not been published. If you own Maltese property below the new threshold and only plan to apply in 2027, wait for them or bring your application forward. With sums of this size, relying on an interpretation that has not yet been written would be an avoidable risk. ## What leaving the UK or Ireland can trigger The Maltese side is only half of the plan. The UK has no general exit tax for individuals: leaving does not trigger a deemed disposal of your shares or investment portfolio. What matters instead is when your UK residence ends and what happens if you come back. The Statutory Residence Test decides whether and when you cease to be UK resident, and split-year treatment may apply in the tax year you leave. The temporary non-residence rules apply if you had sole UK residence in at least four of the seven tax years before the tax year you leave, and you return within five years. Certain income and gains received while you were abroad, including gains on assets you already held before leaving, can then be taxed in the UK in the tax year you return. UK land and property stay within the scope of UK Capital Gains Tax after you leave, under the non-resident CGT rules. Ireland has no general exit tax either, but if you were ordinarily resident there, that status continues for three consecutive tax years after you leave. During that period you can remain liable to Irish tax on most of your worldwide income and, if you are Irish domiciled, on your worldwide capital gains. Both sides belong in the same plan, because the Maltese deadline at the end of 2026 overlaps with the preparations for a clean departure from the UK or Ireland. Our [international tax advisory](https://www.drwerner.com/en/services/tax-advisory/) is the starting point for coordinating both legal systems, complemented by our [HNWI services](https://www.drwerner.com/en/services/hnwi-services/) for high-net-worth individuals. ## Frequently asked questions ### Can I still use the Global Residence Programme? Yes, until 31 December 2026. What matters is that your application reaches the Commissioner for Tax and Customs by that date. An application submitted by then is dealt with on the current terms, even if approval only comes in 2027. ### What happens to my existing status after 31 December 2031? The rules only state expressly that existing cases continue until 31 December 2031. They contain no follow-on provision. A transfer into the Individual Tax Programme on the terms in force at that point is the likely outcome. Administrative guidance on this is still outstanding. ### Do I have to pay the minimum tax if I remit very little to Malta? Yes. The minimum tax is a floor, not an amount you can offset. It is payable regardless of how much foreign income you actually remit to Malta, and it is due in full both in the year the status is granted and in the year it ends. It cannot be refunded. ### Does the flat I have already bought for less than EUR 700,000 still count? Possibly. There is an exception for property bought at a lower price before the new rules come into force. The Commissioner's guidelines have not yet been published, so it is not yet possible to say definitively how far the exception reaches. ### How many days do I have to spend in Malta? The rules set no minimum number of days in Malta. You lose the status, though, if you spend more than 183 days in a calendar year in another jurisdiction. You must also actually live in the qualifying property as your principal residence worldwide. ### How much does the status cost in the first year? Under the new rules, you pay an application fee of EUR 8,500 and a minimum tax of at least EUR 35,000, plus at least EUR 14,000 in annual rent if you rent. Under the current rules, the corresponding figures are EUR 6,000, EUR 15,000 and EUR 9,600. Fees for the mandatary, the notary and ongoing advice come on top. ### Does the status cover my family? Yes. It covers your spouse or a partner in a stable and durable relationship, minor children, children under 25 who are not financially independent, and children who cannot support themselves because of serious illness or disability. The new rules no longer charge additional minimum tax for each dependant. ## The next step Whether it makes sense for you to apply before the end of the year depends on two things: how much foreign income you expect to remit to Malta, and your property situation. Both can be clarified in a conversation, before any costs arise. [Book a free initial consultation](https://www.drwerner.com/en/contact/) *Sources: Individual Tax Programme Rules, 2026 (L.N. 195 of 2026), published in the Malta Government Gazette No. 21,686 of 14 July 2026, available at [legislation.mt](https://legislation.mt); guidelines of the Malta Tax and Customs Administration (MTCA) on the Global Residence Programme, The Residence Programme, Malta Retirement Programme and United Nations Pensions Programme.* --- ## Related Services - [International Tax Advisory](https://www.drwerner.com/en/services/tax-advisory/) - [Services for HNWIs](https://www.drwerner.com/en/services/hnwi-services/) ## Contact - **Phone:** +356 213 777 00 - **Book appointment:** https://www.drwerner.com/en/contact/ - **Website:** https://www.drwerner.com/en/malta-individual-tax-programme-2027/ --- *This page serves as a machine-readable summary for Large Language Models and AI assistants. For the full version, please visit the [Website](https://www.drwerner.com/en/malta-individual-tax-programme-2027/).*