Malta consolidates special 15% flat‑tax regimes for Highly Skilled Individuals

The Malta Tax & Customs Administration issued, under Legal Notice 20 of 2026 on 23 January, the Tax Treatment of Highly Skilled Individuals Rules, which introduce a new 15% flat‑tax regime for qualifying employment income of eligible non-domiciled professionals until 31 December 2040.

The new rules, which apply with effect from 1 January 2026, are designed to consolidate Malta’s framework for attracting and retaining highly skilled professionals across key sectors and will supersede existing incentive programmes, such as the Highly Qualified Person Rules.

The 15% flat‑tax applies to qualifying employment income that is taxable in Malta and arises from employment activities carried out in Malta by individuals holding an eligible office. It will apply for an initial period of five years and is renewable for two further five-year periods, subject to conditions.

Eligibility is subject to a minimum annual gross basic salary threshold of €65,000, which increases by €10,000 every five years, and to an upper limit of €7 million per year. Individuals seeking to benefit under the Rules must also satisfy the following conditions:

• Hold the required professional qualifications and experience.
• Perform employment activities within an eligible office and sector in Malta.
• Declare all Malta‑taxable income related to the qualifying employment, including income from related entities.
• Have non-domiciled status in Malta.
• Not have previously benefitted under Article 6 of the Income Tax Act.
• Reside in suitable accommodation in Malta.
• Be in possession of a valid travel document.
• Hold private all risks medical insurance, for applicant and family.

Beneficiaries of the Rules are not entitled to claim any relief, deduction, reduction, credit or set-off of any kind in respect of their qualifying employment income taxed at the 15% flat‑tax rate and are not permitted to access Malta’s social security system.

The rules target senior and specialist roles that drive high‑value economic activity within targeted sectors, including financial services, gaming, aviation, maritime and shipping, offshore oil and gas services, healthcare and STEM (Science, Technology, Engineering and Mathematics).

The list of eligible offices is set out in the Schedules to the Rules, grouped by industry sector. Applications under the Rules may be made by individuals performing activities that qualify as eligible offices with employers that are regulated, licensed or recognised by any of the following competent authorities:

• The Malta Financial Services Authority (MFSA).
• The Malta Gaming Authority (MGA).
• The Authority for Transport in Malta.
• The Office of the Chief Medical Officer to Government.
• Malta Enterprise.

Eligible offices generally include executive roles, senior management positions and specialised functions that fall within the regulatory remit of the employer and are recognised as eligible by the relevant competent authority.

Applications under the Rules must be submitted to the relevant competent authorities and must specify the year of assessment from which the Rules should apply. Applications are to be processed within 90 days, although the competent authority may, at its discretion, request additional information or documentation.

Individuals who, as at 31 December 2025, qualified as beneficiaries under existing incentive programmes in Malta are permitted, subject to conditions, to apply to be beneficiaries under the new Highly Skilled Individuals Rules. These programmes include:

• Highly Qualified Persons Rules.
• Qualifying Employment in Innovation and Creativity (Personal Tax) Rules.
• Qualifying Employment in Aviation (Personal Tax) Rules.
• Qualifying Employment in Maritime Activities and the Servicing of Offshore Oil and Gas Industry Activities (Personal Tax) Rules.
• Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules.