Legal Notice 195 of 2026, entitled the Individual Tax Programme Rules, 2026, was published on 14 July 2026 under the Income Tax Act (Cap. 123). The Rules introduce a new, consolidated framework for Malta’s special tax residence programmes and will come into force on 1 January 2027.
The new framework consolidates four existing regimes into a single Individual Tax Programme (“ITP”), namely the Global Residence Programme, The Residence Programme, the Malta Retirement Programme and the United Nations Pension Programme. Four corresponding categories of special tax status will therefore be available: Global Resident Status; EU, EEA and Swiss Resident Status; Retired Pensioner Status; and UN Pensioner Status.
Tax benefits
The fundamental tax benefit is retained. Qualifying beneficiaries will generally be subject to tax at 15% on foreign-source income received in Malta, with applicable double taxation relief remaining available. Income which does not qualify for the preferential treatment is generally taxed at 35%. Foreign-source income which is not received in Malta is generally outside the Maltese tax charge under the programme.
The Rules introduce substantially higher minimum annual tax liabilities:
- €35,000 for Global Resident Status and EU, EEA and Swiss Resident Status;
- €15,000 for Retired Pensioner Status; and
- €20,000 for UN Pensioner Status, with qualifying UN pension income retaining its specific exemption.
Main Eligibility and Financial Requirements
Applicants must satisfy the relevant category-specific conditions as well as common requirements, including maintaining a qualifying property in Malta or Gozo as their primary residence, having stable and regular resources, comprehensive health insurance and satisfying the applicable fit-and-proper and domicile requirements. Applicants must also be represented by an Authorised Registered Mandatary.
For new applicants, the qualifying property thresholds are increased to:
- €700,000 minimum purchase price for owned property; or
- €14,000 minimum annual rent for leased property.
The distinction between Malta and Gozo/lower-value areas under the existing regimes is consequently removed for the new programme. The non-refundable application fee is €8,500.
Duration and Ongoing Compliance
Unlike the existing programmes, which generally provide for an indefinite status subject to continuing compliance, ITP status will be granted for an initial five-year period. It may be renewed for further five-year periods, subject to continued compliance and payment of a €2,500 renewal fee.
Beneficiaries must continue to satisfy the programme requirements throughout the period of their status. Relevant cessation events include loss or letting/subletting of the qualifying property, loss of required insurance, failure to pay the applicable minimum tax or submit required filings, loss of the required representation, and spending more than 183 days in another jurisdiction in a calendar year.
Transitional Arrangements
An important feature of LN 195 of 2026 is the transitional protection available to existing beneficiaries and persons who apply under the current regimes before the new Rules take effect. Statuses granted, and applications received, by 31 December 2026 may continue under the existing framework until 31 December 2031.
Conclusion
The Individual Tax Programme represents a significant restructuring of Malta’s special tax residence regime. While the attractive 15% rate on qualifying foreign-source income received in Malta is retained, the new framework imposes materially higher minimum tax liabilities, substantially increased property thresholds, higher application costs and a fixed five-year renewable status. The consolidation of the four existing programmes should simplify administration, while the transitional provisions make 31 December 2026 an important date for individuals considering applying under the current regimes.
The new Rules should therefore be considered not merely as an administrative consolidation, but as a material tightening of the economic and compliance requirements applicable to new applicants from 1 January 2027.
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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