Mt Global Residence Programme

---
name: mt-global-residence-programme
description: "Malta Global Residence Programme for non-EU nationals and its EU, EEA and Swiss twin, the Residence Programme: who can and cannot apply, the qualifying property bought or rented in Malta, Gozo or the south, the flat rate on foreign income brought to Malta and the yearly minimum tax shared by the beneficiary, the spouse and minor or disabled children, Malta-source income, foreign income kept abroad and capital gains, double tax relief, the day limit in any other country, insurance, resources and language conditions, the authorised registered mandatary and its penalty, the application fee, the 30 April payment and return, and what ends the status. Triggers: \"Malta GRP\", \"Global Residence Programme\", \"Malta Residence Programme EU\", \"Malta flat tax on remittances\"."
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/mt-global-residence-programme"
  jurisdiction: "MT"
  tax_year: "2026"
  last_updated: "2026-11-04"
---

# Malta Global Residence Programme and Residence Programme: the flat-rate special tax status

Figures are for tax year 2026. Malta taxes by year of assessment: income of calendar 2026 is assessed in year of assessment 2027, and rule 5(1) of both sets of rules taxes income "arising outside Malta in the year immediately preceding the year of assessment". This Guide covers two parallel sets of rules made under art. 56(23) of the [Income Tax Act, Cap. 123](https://legislation.mt/eli/cap/123/eng/pdf), which applies to an individual who "after 1 January 2011, has been granted a special tax status". The Global Residence Programme Rules, [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf) (L.N. 167 of 2013, amended by L.N. 267 of 2014 and L.N. 69 of 2020), are for third-country nationals. The Residence Programme Rules, [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf) (L.N. 270 of 2014, amended by L.N. 69 of 2020), are for EU, EEA and Swiss nationals who are not Maltese. Both carry the same figures. Both grant a tax status, determined in writing by the Commissioner for Revenue (rule 3(2)); neither grants a residence permit. A comparison with the other Malta routes is in `mt-residence-programmes-for-wealthy-families`, the wider move is in `moving-to-malta-tax-residence`, and residence, domicile and the remittance basis are in `mt-non-dom`. The Malta Permanent Residence Programme is an immigration status: see `mt-permanent-residence-programme`. The nomad permit and its own tax rule are in `mt-nomad-residence-permit`. All amounts in the worked example are hypothetical.

## The figures

### Global Residence Programme Rules, S.L. 123.148 (third-country nationals)

| Item | Value | Note (verbatim) |
| --- | --- | --- |
| Source | all figures below | https://legislation.mt/eli/sl/123.148/eng/pdf |
| Rate on foreign income received in Malta by the beneficiary, the spouse and children in paragraphs (b) and (d) of "dependant" (rule 5(1)) | 15% | "rate of fifteen cents (0.15) on every euro" |
| Minimum tax on the foreign income of those persons together, per year of assessment (rule 5(1) proviso) | EUR 15,000 | "shall be fifteen thousand euro (€15,000) for any year of assessment" |
| Income of the same persons not taxed at the rule 5(1) rate, charged as separate income (rule 5(2)) | EUR 0.35 per euro | "at the rate of thirty-five cents (0.35) on every euro" |
| Qualifying owned property in Malta: purchase price at least (rule 2) | EUR 275,000 | "seventy-five thousand euro (€275,000) for a property situated in Malta" |
| Qualifying owned property in Gozo or the south of Malta: purchase price at least | EUR 220,000 | "two hundred and twenty thousand euro (€220,000) for a property situated in Gozo or in the south of" |
| Qualifying rented property in Malta: rent at least, per year | EUR 9,600 | "nine thousand and six hundred euro (€9,600) per annum for a property situated in Malta" |
| Qualifying rented property in Gozo or the south of Malta: rent at least, per year | EUR 8,750 | "eight thousand and seven hundred and fifty euro (€8,750) per annum for a property situated in Gozo" |
| Application fee, non-refundable, paid on application (rule 3(1)) | EUR 6,000 | "non-refundable administrative fee of six thousand euro (€6,000) upon application" |
| Application fee where the qualifying property is an owned property in the south of Malta (rule 3(1) proviso) | EUR 5,500 | "five thousand and five hundred euro (€5,500)" |
| Penalty on the authorised registered mandatary for a long-term resident notice not made in time (rule 5(4)(b)) | EUR 10,000 | "an administrative penalty of ten thousand euro (€10,000)" |
| Penalty on the person responsible when a cessation event is not notified within four weeks (rule 6(2)) | EUR 5,000 | "administrative penalty of five thousand euro (€5,000)" |
| A body is an authorised mandatary if at least this share of its shareholders, partners or members hold the listed warrants or memberships (rule 2) | 75% | "having at least 75% (directly or indirectly) of its shareholders" |

### Residence Programme Rules, S.L. 123.160 (EU, EEA and Swiss nationals)

| Item | Value | Note (verbatim) |
| --- | --- | --- |
| Source | all figures below | https://legislation.mt/eli/sl/123.160/eng/pdf |
| Rate on foreign income received in Malta by the beneficiary, the spouse and children in paragraphs (b) and (d) of "dependant" (rule 5(1)) | 15% | "rate of fifteen cents (0.15) on every euro" |
| Minimum tax on the foreign income of those persons together, per year of assessment (rule 5(1) proviso) | EUR 15,000 | "shall be fifteen thousand euro (€15,000) for any year of assessment" |
| Income of the same persons not taxed at the rule 5(1) rate, charged as separate income (rule 5(2)) | EUR 0.35 per euro | "at the rate of thirty-five cents (0.35) on every euro" |
| Qualifying owned property in Malta: purchase price at least (rule 2) | EUR 275,000 | "seventy-five thousand euro (€275,000) for a property situated in Malta" |
| Qualifying owned property in Gozo or the south of Malta: purchase price at least | EUR 220,000 | "two hundred and twenty thousand euro (€220,000) for a property situated in Gozo or in the south of" |
| Qualifying rented property in Malta: rent at least, per year | EUR 9,600 | "nine thousand and six hundred euro (€9,600) per annum for a property situated in Malta" |
| Qualifying rented property in Gozo or the south of Malta: rent at least, per year | EUR 8,750 | "eight thousand and seven hundred and fifty euro (€8,750) per annum for a property situated in Gozo" |
| Application fee, non-refundable, paid on application (rule 3(1)) | EUR 6,000 | "non-refundable administrative fee of six thousand euro (€6,000) upon application" |
| Application fee where the qualifying property is an owned property in the south of Malta (rule 3(1) proviso) | EUR 5,500 | "five thousand and five hundred euro (€5,500)" |
| Penalty on the authorised registered mandatary for a permanent resident notice not made in time (rule 5(4)(b)) | EUR 10,000 | "an administrative penalty of ten thousand euro (€10,000)" |
| Penalty on the person responsible when a cessation event is not notified within four weeks (rule 6(2)) | EUR 5,000 | "administrative penalty of five thousand euro (€5,000)" |
| A body is an authorised mandatary if at least this share of its shareholders, partners or members hold the listed warrants or memberships (rule 2) | 75% | "having at least 75% (directly or indirectly) of its shareholders" |

## The method, step by step

1. Test nationality first, for the principal applicant. The Global Residence Programme needs a third-country national who "is not a Maltese, EEA or Swiss national" (rule 4(a), [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)). The Residence Programme needs "an EU, EEA or Swiss national but is not a Maltese national" (rule 4(a), [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf)). A Maltese national can use neither.
2. Test the exclusions. Under the Global Residence Programme the applicant must not be a long-term resident, and an application for long-term resident status already counts (rules 2 and 4, [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)). Under the Residence Programme the applicant must not be a "permanent resident of Malta", and an application for the right of permanent residence already counts (rules 2 and 4, [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf)). The applicant must not benefit under any of the older schemes listed in rule 4(b).
3. Secure a qualifying property holding: an owned property bought for at least, or a rented property leased for at least, the amounts in the tables above, occupied as the primary residence, with only the beneficiary, dependants and household staff living there and the Commissioner notified of them (rule 2, [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)).
4. Evidence the other rule 4 conditions, all of which must be met: stable and regular resources, a valid travel document, sickness insurance, language and fit and proper (rule 4(d) to (h), [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)).
5. Appoint one authorised registered mandatary and apply through that person to the Commissioner, paying the non-refundable fee in the tables above on application (rules 3(1) and 10, [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)). The date of the Commissioner's written determination is the "appointed day" (rules 2 and 3(2)).
6. Each year, sort the income of the beneficiary, the spouse and the paragraph (b) and (d) children: foreign income received in Malta at the rule 5(1) rate, compared with the minimum tax; their other chargeable income at the rule 5(2) rate; double tax relief under art. 74(a) and (b) of the Act (rule 5, [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf); [Cap. 123 art. 74](https://legislation.mt/eli/cap/123/eng/pdf)). Other dependants are taxed under the Income Tax Act.
7. Pay the minimum tax by 30 April of the year immediately preceding the relevant year of assessment, with the return proving the rule 4 conditions still hold (rule 5(3), [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)). File the yearly income tax return with the Commissioner's programme form (rule 9).
8. Diarise the mandatary's 31 December check and 30 April notice on long-term residents (Residence Programme: permanent residents of Malta) (rule 5(4)(b), [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf); [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf)).
9. Watch the cessation events in rule 6(1): nationality, property, long-term or permanent residence, insurance, public interest and days in any other jurisdiction. Notify within four weeks of becoming aware (rule 6(2), [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)).

## Who may apply, and who may not

Global Residence Programme. Under rule 4 of [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf), a beneficiary is an individual who is not a long-term resident and who proves to the Commissioner every one of conditions (a) to (h); the rule joins them with "and". Condition (a) is "he is a third country national and is not a Maltese, EEA or Swiss national". In these rules "EEA" means "the members of the European Union, Iceland, Norway and Liechtenstein" (rule 2). So a person who holds a Maltese, EU, EEA or Swiss nationality as well as a non-EU one does not meet condition (a).

Residence Programme. Under rule 4 of [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf), a beneficiary is an individual who is not a permanent resident of Malta and who proves "he is an EU, EEA or Swiss national but is not a Maltese national", plus the same conditions (b) to (h).

Long-term resident (Global Residence Programme only). Rule 2 of [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf) defines it as a person who has long-term resident status under the Status of Long-term Residents (Third Country Nationals) Regulations (S.L. 217.05), or "a person who applies for long-term resident status" under them. An application alone therefore excludes the person.

Permanent resident of Malta (Residence Programme only). Rule 2 of [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf) defines it as a person who has the right of permanent residence under article 6, and holds a permanent residence certificate under article 7, of the Free Movement of European Union Nationals and their Family Members Order (S.L. 460.17), or a person who applies for that right.

Other special statuses. Rule 4(b) of [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf) excludes a person who benefits under the Residents Scheme Regulations, the High Net Worth Individuals rules (EU/EEA/Swiss and Non-EU/EEA/Swiss), the Malta Retirement Programme Rules, the Qualifying Employment in Innovation and Creativity (Personal Tax) Rules or the Highly Qualified Persons Rules. The list in rule 4(b) of [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf) also names the Global Residence Programme Rules. Neither list names the Malta Permanent Residence Programme or the nomad residence permit; this Guide does not settle whether those can be held together with special tax status.

## The conditions in rule 4

The beneficiary must prove ALL of these at application, under rule 4 of [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf) and [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf):

- (c) he holds a qualifying property holding (next section);
- (d) he is in receipt of "stable and regular resources which are sufficient to maintain himself and his dependants without recourse to the social assistance system in Malta";
- (e) he holds a valid travel document;
- (f) he holds "sickness insurance in respect of all risks across the whole of the European Union normally covered for Maltese nationals for himself and his dependants";
- (g) he "can adequately communicate in one of the official languages of Malta";
- (h) he is a fit and proper person.

The rules print no amount for "stable and regular resources" and no minimum number of days to be spent in Malta. They continue to matter after grant: the yearly return under rule 5(3)(a) must prove that "all the requirements of rule 4 continue to be satisfied", and rule 6(1) ends the status on some of them (see "What ends the status").

## Dependants, and who may live in the property

Rule 2 of [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf) defines a "dependant" as:

- (a) the beneficiary's spouse or person with whom the beneficiary is in a stable and durable relationship;
- (b) minor children (under eighteen), including adopted children and children in the care and custody of the beneficiary or the person in (a);
- (c) children under the age of twenty-five, on the same terms, who are not economically active ("not working and not seeking work or not available for work");
- (d) children who are not minors but who, because of illness or disability "of a serious gravity", are unable to maintain themselves;
- (e) dependent brothers, sisters and direct relatives in the ascending line of the beneficiary or the person in (a);

and in every case the person is not a beneficiary under the older schemes listed in the definition AND resides with the beneficiary in the qualifying property. The Residence Programme definition in [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf) is the same.

Who may live there. A qualifying property holding exists only if "the persons who reside in the qualifying property are not persons other than" the beneficiary and his dependants or household staff, "provided that the Commissioner has been notified that such dependents or household staff will be so residing" (rule 2, [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)). The Residence Programme Rules define "household staff" as an individual employed by the beneficiary under a contract of service for at least two years before the application, where the Commissioner is satisfied the service is needed at least in part in the property (rule 2, [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf)). The Global Residence Programme Rules print the same wording under the term "special carer".

Tax effect. Only the beneficiary, "the beneficiary's spouse" and the children in paragraphs (b) and (d) fall under rules 5(1) and 5(2). Children in paragraph (c) and relatives in paragraph (e) may live in the property, but rule 5 gives their income no rate, so it follows the Income Tax Act. Rule 5 says "spouse" and does not repeat the words "person with whom the beneficiary is in a stable and durable relationship" from paragraph (a).

## The qualifying property

A "qualifying property holding" arises where the beneficiary either owns a qualifying owned property or rents a qualifying rented property as lessee, and in either case occupies that property as his primary residence (rule 2, [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)). A primary residence is the dwelling house in which the individual "habitually resides in as his principal place of abode worldwide". "Property" means immovable property in Malta or Gozo and any right over it. A "lease" includes a sub-lease.

- Owned: bought at a consideration of not less than the purchase price in the tables above, with the lower figure for Gozo or the south of Malta.
- Rented: leased at not less than the yearly rent in the tables above, with the lower figure for Gozo or the south of Malta.
- The south of Malta is the list of localities in the Schedule to the rules: Birżebbuġia, Cospicua, Fgura, Għaxaq, Gudja, Kalkara, Kirkop, Luqa, Marsascala, Marsaxlokk, Mqabba, Paola, Qrendi, Safi, Santa Luċija, Senglea, Siġġiewi, Tarxien, Vittoriosa, Xgħajra, Żabbar, Żejtun and Żurrieq ([S.L. 123.148 Schedule](https://legislation.mt/eli/sl/123.148/eng/pdf)).
- A property bought before the rules were published for less than the threshold still counts if its value declared at the date of application is not less than the threshold, supported by "a separate and independent architect valuation including architect's plan" delivered on application. The Commissioner, an authorised officer, an architect or a surveyor has full and free access to an owned property to check its value (rule 2).
- The reduced application fee in the tables above applies only where the qualifying property is an OWNED property in the south of Malta. A rented property, or any property in Gozo, pays the standard fee (rule 3(1) proviso, [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)).
- Letting or subletting the property ends the status (rule 6(1)(b)).

## What is taxed, and at what rate

Foreign income received in Malta. Rule 5(1) of [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf) and [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf) applies the rate in the tables above ("fifteen cents (0.15) on every euro") to "any income arising outside Malta in the year immediately preceding the year of assessment which is received in Malta". In the year status is granted it covers foreign income "received in Malta during the whole of the year in which the special tax status was granted", not only the part after grant. It covers the income of the beneficiary, the spouse and the paragraph (b) and (d) children. Outside the year of grant, the words cover only foreign income arising in the year immediately preceding the year of assessment; the rules do not say how foreign income that arose in an earlier year and is received in Malta later is taxed.

The minimum tax. The "minimum amount of tax payable in terms of these rules in respect of the income arising outside Malta of the persons referred to in this rule" is the minimum in the tables above, "for any year of assessment" (rule 5(1) proviso). It is one minimum for the beneficiary, spouse and those children together, not one each. It "is payable in full in both the year when the special tax status was granted and in the year when the individual ceases to possess the said special tax status": the rules print no reduction for a part year.

Malta-source and other income. Income of the same persons "that is not chargeable to tax under these rules at the rate referred to in sub-rule (1) shall be charged as separate income" at the rule 5(2) rate in the tables above. That catches their Malta-source income. The rules print this one rate; they do not apply the art. 56(1) bands of [Cap. 123](https://legislation.mt/eli/cap/123/eng/pdf). The rules do not say how rule 5(2) works where the Act already taxes a Malta item by a final tax or a special rate.

Long-term residents (Residence Programme: permanent residents of Malta). Rule 5(4)(a) of [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf) makes such an individual taxable "on any income accruing in or derived from Malta or elsewhere, and whether received in Malta or not", at the rates in art. 56 of the Act. The same applies to a "permanent resident of Malta" under [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf).

Foreign income not received in Malta. Rule 5(1) reaches foreign income only when it "is received in Malta". The rules do not name foreign income that stays abroad. Rule 5(2) charges at its rate any income of the same persons "that is not chargeable to tax under these rules at the rate referred to in sub-rule (1)", so foreign income kept abroad falls there only if the Act makes it chargeable; rule 5(4)(a) covers long-term residents. Whether such income is taxed depends on art. 4(1) of [Cap. 123](https://legislation.mt/eli/cap/123/eng/pdf): under proviso (i), for a person who is not ordinarily resident or not domiciled in Malta, tax on income arising outside Malta "shall be payable on the amount received in Malta". The rules do not themselves require the beneficiary to be non-domiciled. Domicile, ordinary residence and the carve-outs to art. 4(1) are in `mt-non-dom`.

Capital gains. The rules print no rule and no rate for capital gains; rule 5(1) speaks only of "income arising outside Malta". Under art. 4(1) proviso (ii) of [Cap. 123](https://legislation.mt/eli/cap/123/eng/pdf), "no tax shall be payable on capital gains arising outside Malta to a person who is not ordinarily resident in Malta or not domiciled in Malta". That exemption comes from the Act, not from the programme, and depends on the person's ordinary residence or domicile: see `mt-non-dom`.

Double tax relief. Rule 5(1) adds "with the possibility to claim relief of double taxation under article 74(a) and (b) of the Act". In [Cap. 123 art. 74](https://legislation.mt/eli/cap/123/eng/pdf), (a) is "double taxation relief, as provided in articles 76 to 78" and (b) is "unilateral relief, as provided in articles 79 to 88". Rule 5(1) does not name (c), relief for Commonwealth income tax, or (d), the flat-rate foreign tax credit. The rules do not say whether relief can take the tax below the minimum.

The non-dom minimum tax. Art. 56(27) of [Cap. 123](https://legislation.mt/eli/cap/123/eng/pdf) applies only to a non-domiciled individual "who is not taxable in accordance with any scheme under the Act effectively establishing a minimum tax payable". These rules set such a minimum. The non-dom minimum is in `mt-non-dom`.

## Payment, the yearly return and filing

- The minimum tax "shall be payable by not later than the 30th April of the year immediately preceding the relevant year of assessment" (rule 5(3)(a), [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)). For year of assessment 2027 (income of 2026), that is 30 April 2026.
- The payment is "accompanied by a return made to the Commissioner that provides proof that all the requirements of rule 4 continue to be satisfied", in the form the Commissioner sets. That return "does not need to be submitted in the year in which the special tax status is granted" (rule 5(3)(a)).
- In the year of grant, "where, it is evident that the special tax status will not be granted before the 30th April", the minimum tax is paid before status is granted (rule 5(3)(b)).
- "any tax paid under the provisions of sub-rule (1) shall not be refundable" (rule 5(3)(c)).
- The yearly income tax return under article 10 of the Income Tax Management Act (Cap. 372), for a beneficiary, "includes such form as the Commissioner may require" (rule 9). The rules print no other filing date; the return itself is in `malta-income-tax`.
- The [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf) rules 5(3) and 9 say the same.

## The authorised registered mandatary

Who can act. An "authorised mandatary" is a warranted advocate or legal procurator, a notary public, a person holding a warrant to practise as an accountant under the Accountancy Profession Act, or a member of the Institute of Financial Services Practitioners, the Malta Institute of Taxation, the Malta Institute of Accountants or the Institute of Management. A body that is not an individual also qualifies if at least the share in the tables above of its shareholders, partners or members, directly or indirectly, hold those warrants or memberships. An "authorised registered mandatary" is one registered with the Commissioner (rule 2, [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)).

What the mandatary does. The individual applies as represented by an authorised registered mandatary (rule 3(1)). The individual authorises one such person to act on all applications, correspondence, submissions, filings, declarations and notifications under the rules, all filed by that mandatary. A person may not authorise more than one mandatary unless the Commissioner authorises it in writing. A mandatary who fails more than twice to carry out a function under the rules ceases to be an authorised registered mandatary (rule 10). The Commissioner may require the individual or the mandatary to produce information and documents within the time the Commissioner sets (rule 7(1)).

The yearly residence check. The mandatary must ask whether the beneficiary or any dependant was a long-term resident "as at the 31st December of each year from the year of the appointed date onwards" and notify the Commissioner of any such person "by not later than the 30th April following". If the information cannot be obtained, the mandatary notifies the Commissioner of that by the same 30 April with proof of at least two attempts at enquiry. If the notice is not made in time, the mandatary is charged the penalty in the tables above (rule 5(4)(b), [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)). Under the Residence Programme the check is for a "permanent resident of Malta", and rule 5(4)(b) there names household staff as well as beneficiaries and dependants ([S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf)).

## Application, grant, and death of the beneficiary

- The application is made to the Commissioner "in such form as the Commissioner may require", with the non-refundable fee in the tables above paid "upon application" (rule 3(1), [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)).
- Where the individual qualifies, the Commissioner determines in writing that status is granted; that date is the "appointed day" (rules 2 and 3(2)).
- On the death of a beneficiary, status is granted to a dependant who inherited the property that was the beneficiary's primary residence, or who rents a qualifying rented property immediately after the death, and who satisfies all the other rule 4 requirements. It transfers only once that dependant proves the rule 4 requirements are met (rule 3(3), [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf); same in [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf)).
- If an individual benefits under the rules without being entitled, the Commissioner may issue an assessment under article 31 of the Income Tax Management Act (rule 8).

## What ends the status

Rule 6(1) of [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf) says an individual "shall, with effect from the appointed day, cease to possess special tax status" if ANY ONE of these happens:

- (a) the individual becomes a Maltese, EEA or Swiss national (Residence Programme: "becomes a Maltese national or a third country national", [S.L. 123.160](https://legislation.mt/eli/sl/123.160/eng/pdf));
- (b) at any time after the appointed day, the individual does not hold a qualifying property holding, "including in the case where the said individual lets or sublets the qualifying property holding";
- (c) at any time after the appointed day, the individual becomes a long-term resident (Residence Programme: a permanent resident of Malta);
- (d) after the appointed day, the individual does not hold sickness insurance "in respect of all risks normally covered for Maltese nationals for himself and his dependants";
- (e) the individual's stay is not in the public interest;
- (f) the individual "stays in any other jurisdiction for more than one hundred and eighty-three days in a calendar year".

The day test in (f) counts days in another jurisdiction, more than the printed number in a calendar year. The rules print no minimum number of days in Malta.

Notice and penalty. The individual must notify the Commissioner "by not later than four weeks from the date when he becomes aware of such event", on the Commissioner's form. If not, "the person responsible for such event" is charged the penalty in the tables above (rule 6(2)).

Other endings.
- Giving up the status: the individual ceases "with immediate effect" to possess special tax status "from the relative year of assessment" on notifying the Commissioner of the intention not to keep it (rule 6(3)).
- Breach of the Income Tax Act or the Income Tax Management Act: status ends "with effect from the beginning of the relative year of assessment" (rule 6(4)).
- The minimum tax is payable in full in the year status ends (rule 5(1) proviso).

Condoning a failure. The Minister responsible for Finance and the Minister responsible for the Economy, Investment and Small Business may jointly condone a failure to satisfy any one of the rule 6(1) conditions only if ALL three hold: the failure was due to unforeseen circumstances beyond the individual's control, the individual notifies the Ministers, and the individual "has exercised his best efforts to remedy the failure" (rules 2 and 6(5), [S.L. 123.148](https://legislation.mt/eli/sl/123.148/eng/pdf)).

## Worked example (hypothetical): the minimum tax bites

All amounts in this section are hypothetical. Facts: a married couple, both third-country nationals with no Maltese, EU, EEA or Swiss passport. The husband is the beneficiary and holds Global Residence Programme status for the whole of 2026 (not the year of grant or the year it ends); his wife lives with him. They rent a home in Malta, outside the south, at a rent of at least the figure in the tables above, and live there with their son aged 10. Their daughter aged 22, at university and not economically active, also lives with them. In 2026 the husband brings to Malta foreign dividends paid to him in 2026 and the wife brings to Malta foreign rental income arising in 2026, with no foreign tax paid on either. The husband also earns Malta-source consultancy fees. They keep further foreign income abroad.

| Item | Hypothetical amount | How it is computed |
| --- | --- | --- |
| Source | all figures below | https://legislation.mt/eli/sl/123.148/eng/pdf |
| A. Foreign income received in Malta by the husband (beneficiary) | EUR 40,000 | Assumed |
| A. Foreign income received in Malta by the wife (spouse) | EUR 20,000 | Assumed |
| A. Foreign income received in Malta, both together | EUR 60,000 | EUR 40,000 plus EUR 20,000 |
| A. Charge at the rule 5(1) rate | EUR 9,000 | 15% of EUR 60,000 |
| A. Tax on foreign income: the higher of that charge and the minimum tax | EUR 15,000 | The minimum tax applies |
| A. Malta-source consultancy fees of the husband | EUR 4,000 | Assumed |
| A. Tax on the fees at the rule 5(2) rate | EUR 1,400 | EUR 0.35 per euro on EUR 4,000 |
| A. Total for year of assessment 2027, before any double tax relief | EUR 16,400 | EUR 15,000 plus EUR 1,400 |
| B. Same family, foreign income received in Malta, both together | EUR 120,000 | Assumed |
| B. Charge at the rule 5(1) rate, above the minimum tax, so this is the tax on foreign income | EUR 18,000 | 15% of EUR 120,000 |

Reading the example ([S.L. 123.148 rule 5](https://legislation.mt/eli/sl/123.148/eng/pdf)):
- The husband's and wife's remitted foreign income is added together, because the minimum tax is set "in respect of the income arising outside Malta of the persons referred to in this rule", one minimum for them all.
- The foreign income kept abroad is not charged under rule 5(1), which reaches only income "received in Malta".
- The Malta-source fees are charged under rule 5(2) on top of the minimum. The minimum is set only for "the income arising outside Malta".
- The minimum in line A was due by 30 April 2026, with the rule 4 return (rule 5(3)(a)).
- The son is a paragraph (b) dependant, so any foreign income of his received in Malta would join the pool. The daughter is a paragraph (c) dependant: she may live in the home, but rule 5 gives her income no rate, so her income follows the Income Tax Act.
- The rules do not print how the part of line B above the minimum already paid by 30 April is settled; ask the authorised registered mandatary.

## Ask the client first

- What nationality does each family member hold, including any Maltese, EU, EEA or Swiss passport? This decides which set of rules is open, or whether either is.
- Does anyone hold, or plan to apply for, long-term resident status (S.L. 217.05) or, for EU nationals, the right of permanent residence (S.L. 460.17)? For the principal even an application excludes or ends the status (rules 2, 4 and 6(1)(c)); for any family member it brings worldwide taxation at the art. 56 rates (rule 5(4)(a)). Is the principal a beneficiary under the High Net Worth Individuals, Highly Qualified Persons or other scheme listed in rule 4(b)?
- Will they buy or rent, in which locality, at what price or rent, and will anyone other than dependants and notified household staff live there, or will any part be let?
- How much foreign income (not capital and not gains) will the beneficiary, the spouse and the minor or disabled children bring to Malta each year, how much Malta-source income is there, and what foreign tax is paid on it?
- How many days a year will the principal spend in each other country?
- Who will live in the home: children with ages and whether they work or study, parents, siblings, staff with contracts of service?

## When to refuse or refer

- Immigration permits are out of scope. Neither set of rules grants residence. For the permanent residence programme use `mt-permanent-residence-programme`; for the nomad permit use `mt-nomad-residence-permit`.
- A beneficiary who may be domiciled or ordinarily resident in Malta, and any question whether foreign income kept abroad or a foreign gain is taxed: refer, using `mt-non-dom`. The rules do not decide it.
- Double tax relief against the rule 5(1) rate, and whether relief can take the tax below the minimum: refer to an adviser with the treaty in hand.
- Malta income that the Act already taxes by a final tax or a special rate (rents, investment income): the rules do not say how rule 5(2) applies; refer.
- An unmarried partner's foreign income, given that rule 5 says "spouse": refer.
- The timing of a loss of status under rule 6(1) ("with effect from the appointed day"), and any request to the Ministers to condone a failure under rule 6(5): refer to the authorised registered mandatary or an advocate.
- Beneficiaries of the older High Net Worth Individuals rules or the Residents Scheme: out of scope.
- Foreign income that arose in an earlier year (for example before the status was granted) and is brought to Malta later: rule 5(1) does not say how it is taxed; refer.
- Refuse to state an amount for "stable and regular resources" or a minimum number of days in Malta: the rules print neither.

## Sources

- Global Residence Programme Rules, S.L. 123.148: https://legislation.mt/eli/sl/123.148/eng/pdf (read 2026-11-04; read for rules 2 to 6 programme conditions, figures and hypothetical).
- Residence Programme Rules, S.L. 123.160: https://legislation.mt/eli/sl/123.160/eng/pdf (read 2026-11-04; read for rules 2 to 6 comparative programme conditions and figures).
- Income Tax Act, Cap. 123 (consolidated; art. 4(1), art. 56(23), art. 56(27), art. 74): https://legislation.mt/eli/cap/123/eng/pdf (read 2026-11-04, articles 5, 5A and 31D for the targeted corrections; unchanged wider claims not re-certified).

This Guide is general information for tax year 2026, not advice on a particular family's affairs. Confirm current figures on the official sources above before acting.


### Targeted audit source checks, 4 November 2026

Removed the PDF marginal-heading extraction artifact from the quoted notes; rates and eligibility rules are unchanged. Previous review metadata is not carried onto this revised text. Unread immigration and brochure-only conditions remain held. This is a source-cited draft; the targeted corrections do not certify every unchanged rule.

- S.L. 123.148 rule 5(1): https://legislation.mt/eli/sl/123.148/eng/pdf (read 2026-11-04; read for rule 5(1), rate quotation).
- S.L. 123.160 rule 5(1): https://legislation.mt/eli/sl/123.160/eng/pdf (read 2026-11-04; read for rule 5(1), rate quotation).

Not yet confirmed: all legacy-source claims outside the targeted read scopes above, including unread portal, subsidiary-rule and immigration conditions, retain their stated holds. A reference retained here is not proof of a fresh read.

## Targeted executable checks of the existing hypothetical

These reproduce the existing hypothetical with no foreign tax and no double-tax relief. The minimum is on the covered foreign income, while the hypothetical Malta consultancy fees are additional at 35%.

```oa-check
name: GRP foreign-income minimum plus separate Malta-source fees
inputs:
  foreign_income: 60000
  malta_fees: 4000
steps:
  - foreign_charge: pct(foreign_income,15)
  - foreign_tax: max(foreign_charge,15000)
  - local_tax: pct(malta_fees,35)
  - total: foreign_tax + local_tax
expected:
  foreign_charge: 9000
  foreign_tax: 15000
  local_tax: 1400
  total: 16400
```

```oa-check
name: GRP remittances above the minimum crossover
inputs:
  foreign_income: 120000
steps:
  - foreign_tax: max(pct(foreign_income,15),15000)
expected:
  foreign_tax: 18000
```

## Today's figures and who stands behind this skill

This file is an AI skill (tax rules your AI follows) from OpenAccountants, copied on 2026-11-04. Rates, thresholds and deadlines change. For the current version of this skill, its official sources and the named accountant (if any) who stands behind it, call `get_skill` with slug `mt-global-residence-programme` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/mt-global-residence-programme. If neither is available, confirm every figure against the official source pages cited above before relying on it.