Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules

On 17 October 2025, the Malta Tax & Customs Administration (the ‘MTCA’) announced new tax rules of interest to senior professionals working with family offices, back offices and treasury management operations.

Through the publication of  Legal Notice 250 of 2025, implementing the Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules, 2025 (the ‘Rules’), qualifying beneficiaries in eligible roles (as described below) may benefit from a reduced flat rate of income tax of 15% on employment income, subject to conditions.

Eligible roles include senior management positions such as Chief Executive Officer, General Manager, Country Head, Managing Director, Head of Back Office, Chief or Head Risk Officer, Chief or Head Compliance and Anti-Money Laundering Officer, Portfolio Manager, Chief or Head Investment Officer, Senior Trader, and Senior Structuring Professional. These roles must be held with qualifying single or multi-family offices duly licenced by the Malta Financial Services Authority, as well as entities providing back office or treasury management services to such undertakings, as confirmed by the Malta Financial Services Authority.

With a retrospective entry into force date of 1 January 2025 and applicable from Year of Assessment 2026, beneficiaries must meet a number of conditions, including inter alia that they are employed in Malta under a contract in an eligible office and must receive annual emoluments of at least €65,000, which shall be adjusted upwards by €10,000 every five years.

With the Rules targeting expats seeking employment in the aforementioned positions, qualifying beneficiaries are also required to possess relevant professional qualifications or, alternatively, a minimum of five years of comparable professional experience. Other requirements set out within the Rules include having sufficient stable resources, living in suitable accommodation in Malta, holding valid travel documents, maintaining private medical insurance covering beneficiaries and their family, and not being domiciled in Malta.

The 15% tax rate applies to employment income from eligible roles up to €7,000,000 per year. Income in excess of €7,000,000 shall be chargeable at the rate of 35%.

Applications are to be submitted between 1 January 2025 and 31 December 2034 and are expected to be processed within 90 days of the submission of all the relevant documentation. Beneficiaries are eligible to benefit from the Rules for a period of five years, with the option of two further extensions of five years each, subject to conditions. The benefits under the Rules shall not apply beyond 31 December 2040.

Deloitte’s view

The introduction of these rules provides a competitive tax regime for senior professionals in the family office and private wealth management sector, subject to strict eligibility and compliance requirements. We recommend that affected individuals and employers review their contracts and ensure all conditions are met prior to application.

Deloitte Malta remains available to assist clients with eligibility assessments, application preparation, and ongoing compliance under the Rules.