Individual Tax Programme Rules, 2026

On 14 July 2026, the Government of Malta published Legal Notice 195 of 2026, introducing the Individual Tax Programme Rules, 2026 (the ‘Rules’), which will come into force on 1 January 2027.

The Rules establish a unified tax framework for individuals seeking special tax status in Malta. Notably, the Rules streamline the special individual tax regimes by consolidating and amalgamating legacy programmes.

The new unified programme categorises special tax status into four distinct cohorts:

1. Global Resident Status;
2. EU, EEA, Swiss Resident Status;
3. Retired Pensioner Status; and
4. UN Pensioner Status.

Duration and transitional arrangements

The status granted in terms of the Rules is for a term of five years, with the option to renew for further five-year periods, subject to meeting ongoing criteria. Transitional provisions have also been included for beneficiaries, and applications made on or before 31 December 2026, in terms of the current available framework which shall subsist until 31 December 2031.

Key changes

Whereas qualifying criteria have largely remained the same, the Rules contemplate a significant revision to the minimum qualifying property thresholds, tax liability and administration costs, with compliance obligations and cessation triggers further tightened for a more robust framework, including key changes to the definition of authorized registered mandatory, and introduction of a definite term, which may be renewed, for tax status granted for the purposes of the Rules. 

Tax treatment and minimum tax thresholds

Qualifying beneficiaries will continue to enjoy a flat tax rate of 15% on foreign source remittances, with the possibility of claiming double taxation relief. Other non-qualifying income remains subject to tax at 35%.

Continuous adherence to a number of conditions is critical to retain the special tax status afforded in terms of the Rules, inter alia including a minimum annual tax liability of EUR 35,000 applicable to beneficiaries falling within the Global Resident Status and EU, EEA, Swiss Resident Status whereas beneficiaries under Retired Pensioner Status and UN Pensioner Status are subject to a minimum tax liability of EUR 15,000 and EUR 20,000 respectively. Notably, these minimum annual tax thresholds have been increased compared to the previous legacy schemes.

Deloitte’s view

The publication of these consolidated rules represents a significant shift, bringing previously separate schemes under a single, unified framework to streamline administration and enhance clarity. While the beneficial 15% tax rate on foreign-source income is preserved, the transition to the new Individual Tax Programme highlights the critical importance of structured reporting and ongoing compliance.

Deloitte remains available to assist clients with eligibility assessments, property arrangement reviews, and managing the application and transition processes under these new Rules.