Through Legal Notice 20 of 2026, Malta introduced the Tax Treatment of Highly Skilled Individual Rules (the “2026 Rules”), which came into force on the 1st of January 2026. These rules establish a dedicated tax framework for qualified professionals employed in Malta, subject to prescribed conditions and limited to specified sectors, including financial services and gaming, aviation and maritime, as well as STEM and healthcare, among others.
The 2026 Rules repeal and replace several pre-existing regimes, including the Qualifying Employment in Aviation (Personal Tax) Rules and the Qualifying Employment in Maritime Activities and the Servicing of Offshore Oil and Gas Industry Activities (Personal Tax) Rules. The legislative intent is to ensure greater cohesion, uniformity, and consistency in the fiscal treatment of highly skilled individuals working in Malta.
To qualify under the 2026 Rules, an individual must earn a minimum annual employment income of €65,000, exclusive of fringe benefits. This threshold is scheduled to increase by €10,000 every five years.
Furthermore, to be recognised as a “beneficiary,” the individual must possess relevant academic qualifications or, at least five years of comparable professional experience, and must qualify as an employee under Maltese law while performing duties in an eligible office.
Additional eligibility requirements include residence in suitable accommodation in Malta, possession of private medical insurance covering the individual and any dependants, a valid travel document, and non-domiciled status in Malta at the time of application. The individual must also demonstrate that they have stable and regular financial resources sufficient to support themselves and their family without recourse to Malta’s social assistance system.
Qualifying individuals benefit from a preferential flat tax rate of 15% on employment income. This rate applies to annual emoluments of up to €7,000,000, with any excess income taxed at the standard applicable rates.
The tax benefit is granted for an initial period of five years. Beneficiaries may apply for two additional five-year extensions, potentially resulting in a maximum benefit period of fifteen years, provided continued compliance with the applicable conditions. In any event, no benefits under the 2026 Rules shall apply to income earned after the 31st of December of 2040.
The Commissioner for Tax and Customs is empowered to request supporting documentation to verify eligibility. Where benefits are obtained through artificial arrangements, the Commissioner may revoke such benefits and issue tax assessments to recover any tax due.
