Guidelines in relation to the tax treatment of Highly Skilled Individuals Rules

On 7 April 2026, the Malta Tax & Customs Administration published new guidelines clarifying the application of the Tax Treatment of Highly Skilled Individuals Rules (the ‘HSIR’).

Building on the harmonised framework introduced by the HSIR and previously highlighted in our tax alert of 26 January 2026, these guidelines provide further detail for qualifying expatriates in regulated industries.

The new guidelines address:

• Minimum income requirements, including scheduled increases every five years and pro-rata adjustments for partial year contracts;
• Clarification of eligible offices and roles;
• Application and renewal procedures, including documentation and timing; and
• Transitional provisions for applicants under previous programmes.

These guidelines are relevant to expatriates and employers in financial services, gaming, aviation, maritime, innovation, and family office sectors, as well as those seeking to benefit from Malta’s competitive tax regime for highly skilled professionals.

Global Employer Services

The publication of these guidelines provides welcome clarity and operational detail for both individuals and employers seeking to benefit from the new harmonised regime. Deloitte recommends reviewing eligibility, documentation, and application deadlines to ensure compliance and maximise benefits.

Deloitte remains available to assist with eligibility assessments, application preparation, and ongoing compliance under the Highly Skilled Individuals Rules.