Applications must be formally submitted by 31 December 2026
Malta is introducing significant changes to its special tax residence programmes from 1 January 2027.
The existing Global Residence Programme, The Residence Programme, Malta Retirement Programme and United Nations Pensions Programme will be brought together under the new Individual Tax Programme. Although the preferential 15% tax rate will remain, future applicants will face substantially higher minimum tax liabilities, property thresholds and government fees. Special tax status will also be granted for a limited five-year period and will require renewal.
There is, however, an important transitional opportunity.
Individuals whose special tax status is granted by 31 December 2026, as well as applicants whose applications are formally received by the Maltese tax authorities by that date, may continue to benefit from the existing, more favourable conditions until 31 December 2031, provided that they continue to satisfy the programme requirements.
For individuals already considering relocation, retirement or tax residence in Malta, the remaining months of 2026 may therefore represent a valuable planning window.
Which programmes are changing?
The reform affects Malta’s main special tax residence programmes:
- The Global Residence Programme, primarily intended for qualifying non-EU nationals;
- The Residence Programme, available to qualifying EU, EEA and Swiss nationals;
- The Malta Retirement Programme, designed for qualifying pensioners.
From 1 January 2027, these programmes will be consolidated within one legislative framework, with applicants classified under the relevant category of special tax status.
What will change from 1 January 2027?
The 15% tax rate on qualifying foreign-source income remitted to Malta will remain one of the central features of the new programme. Other income may remain subject to different rates, depending on its source and the applicant’s circumstances.
The principal changes concern the minimum financial commitments required to enter and maintain the programme.
| Requirement | Current conditions | From 1 January 2027 |
|---|---|---|
| Minimum annual tax under TRP or GRP | €15,000 | €35,000 |
| Minimum annual tax under MRP | €7,500, plus €500 per dependent | €15,000 |
| Minimum property purchase | €220,000 in Gozo or the South of Malta; €275,000 elsewhere | €700,000 |
| Minimum annual property rent | €8,750 in Gozo or the South of Malta; €9,600 elsewhere | €14,000 throughout Malta and Gozo |
| Government application fee | Varies under the current programme | €8,500 |
| Duration of special tax status | Ongoing, subject to continued compliance | Five years |
| Renewal fee | Not generally applicable | €2,500 for each renewal |
The increases are particularly significant for applicants under The Residence Programme and Global Residence Programme, where the minimum annual tax will rise from €15,000 to €35,000.
Retirement applicants will also see the minimum annual tax increase from €7,500, plus €500 for each dependent, to €15,000. The current reduced property thresholds available for Gozo and the South of Malta will be removed.
The 15% preferential tax rate will remain
The reform does not remove Malta’s preferential tax treatment.
Qualifying beneficiaries will generally continue to benefit from a 15% tax rate on foreign-source income received in Malta, subject to the applicable minimum annual tax and the possibility of claiming double-taxation relief.
Income and capital gains arising in Malta may be subject to tax at 35%, while foreign capital gains may receive different treatment depending on the applicant’s residence and domicile position.
Each applicant’s income should therefore be reviewed individually before an application is submitted.
How can the current conditions be secured?
The transitional provisions are one of the most important elements of the reform.
Special tax statuses granted on or before 31 December 2026, together with applications received by the authorities by that date, may continue under the existing programme conditions until 31 December 2031.
This protection may apply even where the application is approved during 2027, provided that it was properly submitted and formally received before the year-end deadline.
In practical terms, qualifying applicants may be able to preserve:
- the current lower minimum annual tax;
- the current reduced purchase and rental thresholds;
- the current programme-specific application fee; and
- the current programme conditions until the end of 2031.
The preferential treatment remains conditional on the beneficiary continuing to satisfy all relevant eligibility, property, insurance, tax and compliance requirements.
Why you should not wait until December
The legal deadline is 31 December 2026, but this should not be treated as the practical date on which to start the process.
The application must be prepared, completed and formally received by the Maltese authorities. Depending on the programme and the applicant’s circumstances, the preparation process may include:
- an initial eligibility and tax assessment;
- identification of the most appropriate programme;
- due-diligence and source-of-wealth documentation;
- police conduct certificates;
- evidence of pension or other income;
- health insurance covering the required risks;
- qualifying property purchase or rental agreement;
- certified and legalised personal documents; and
- preparation and review of the official application forms.
Applications may only be submitted through an Authorised Registered Mandatary. Documentation from several jurisdictions may also require apostille, legalisation, certification or official translation.
Applicants who begin the process late in the year may therefore face practical difficulties in completing the required documentation before the authorities close for the holiday period.
Anyone wishing to benefit from the current conditions should ideally begin the eligibility and document-review process well before December 2026.
Who should consider applying before the deadline?
The transitional window may be particularly relevant to:
- non-EU nationals considering the Global Residence Programme;
- EU, EEA or Swiss nationals considering The Residence Programme;
- pensioners intending to retire or spend more time in Malta;
- internationally mobile families planning to establish their principal residence in Malta; and
- existing Malta residents who have not yet formalised their special tax status.
Applying under a special tax programme is not automatically suitable for every individual. The applicant’s nationality, residence intentions, income composition, pension arrangements, property position and connections with other jurisdictions must all be considered.
Special tax status is also distinct from ordinary tax residence and from immigration or permanent residence status. The appropriate structure should therefore be assessed from both a tax and residence perspective.
A five-year opportunity, but a limited application window
The current conditions may remain available until 31 December 2031, but only for existing beneficiaries and qualifying applications submitted within the 2026 transitional window.
From 1 January 2027, new applicants will enter a materially more expensive framework, including higher annual tax commitments, a €700,000 property purchase threshold, an €8,500 application fee and mandatory five-year renewals.
For individuals who are already planning to relocate or retire in Malta, bringing the application forward may result in substantial savings over the transitional period.
How 1st Step Solution can assist
1st Step Solution is authorised to act as an Authorised Registered Mandatary and can support applicants throughout the entire process.
Our assistance includes:
- preliminary eligibility assessment;
- comparison of the available Malta programmes;
- review of income and tax-residence circumstances;
- preparation of the application and supporting documentation;
- coordination of due-diligence and compliance requirements;
- submission of the application to the Maltese authorities; and
- ongoing assistance with annual programme obligations.
Individuals interested in securing the current conditions should contact us as early as possible to establish eligibility and prepare a realistic application timetable.
Applications must be formally received by 31 December 2026. Starting the process early is essential.
This article is intended for general informational purposes and does not constitute legal or tax advice. Eligibility and tax treatment depend on the applicant’s individual circumstances and continued compliance with the applicable programme conditions.