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Malta offers an interesting scheme for foreign individuals who relocate to Malta. The High Net Worth Individuals (HNWIs) Schemes have been launched in September 2011 offering interesting tax planning opportunities for foreigners who take up residence in Malta.

The Schemes replace a previous scheme called the Residents Scheme. Residents Scheme permit holders retained their existing rights but are required to satisfy certain additional conditions as discussed below. The main characteristics of the HNWIs Schemes are similar to those prescribed under the old Residents Scheme – namely, the requirement to acquire or rent property in Malta and the entitlement to a special rate of tax on foreign income that is remitted to Malta. However, the HNWIs Scheme contains additional conditions.

Main features of the HNWIs Schemes

One HNWIs scheme is aimed at nationals of the EU, EEA and Switzerland whereas another scheme is aimed at HNWIs who are not nationals of the EU, EEA or Switzerland. Unlike other foreigners living in Malta, qualifying HNWIs are subject to Maltese tax at a reduced rate of 15% on foreign income (excluding capital gains) that is received in Malta.

Acquisition of property in Malta is a straightforward process and there are no capital or property taxes in Malta. A ‘stamp duty’ of 5% on the value of the property is due by the buyer at the time of purchase. No VAT is due on the acquisition of property. When foreigners sell their property (for instance in the course of exiting from the HNWIs or Residents Scheme), they are entitled to an exemption from capital gains tax in certain cases. No stamp duty or VAT is due on the letting of property. For further information about the tax treatment of the sale of property in Malta, please click here. No stamp duty or VAT is due on the letting of property.

Below are the main conditions prescribed by the new HNWIs Schemes:

EU/EEA/Swiss nationals

• Qualifying individuals must not reside in any another country from more than 183 days in a year
• Applicants are required to purchase property in Malta worth a minimum of €400,000 or rent property at a minimum rent of €20,000 a year and use such property as their principal place of residence. The property may not be let or sub-let.  An applicant need not be the owner or lessee of a qualifying property at time of application.  
• Applicants and his/her family members will be required to declare that they occupy the above property as their principal place of residence worldwide
• Applicants must be in receipt of stable and regular resources that are sufficient to maintain himself / herself and the dependents without recourse to the social assistance system in Malta
• Applicants and their family members/dependants must be covered by a health & medical insurance covering all EU territories
• Qualifying individuals are subject to Maltese tax at 15% on foreign income that is received in Malta (remittance basis) and are entitled to double taxation relief (where applicable). The minimum annual tax is €20,000 for the qualifying individual plus an additional annual tax of €2,500 for every dependant living with the individual. 
• Other income derived by the beneficiary and his or her spouse that is subject to Maltese tax will be taxed at 35%
• The applicant must not be a Maltese citizen or domiciled in Malta. Furthermore, the applicant must not intend to establish domicile in Malta within 5 yeas from the date of submitting an application under the HNWI scheme. 

NON EU/EEA/Swiss nationals

The main conditions are the same as those applicable to EU/EEA/Swiss citizens (above) with the following exceptions/additions-

• The annual minimum tax is €25,000 and an additional annual tax of €5,000 for every dependant living with the permit holder
• A person who declares (at the time of submitting an applicaiton) that he intends to become a long-term resident of Malta is required to enter into a 'Qualifying Contract' with the Maltese Government providing a financial bond in favour of Government. If the applicant declares that he has no intention of becoming a long-term resident, the applicant may not stay in Malta for more than 9 months in a calendar year
• The applicant must not be domiciled in Malta and does not intend to establish his domicile in Malta within 5 years from the date of submitting an application
• The applicant must be fluent in English or Maltese

Residents Scheme certificate holders

An individual who had acquired rights under the Residents Scheme Regulations before 1 January 2011 will continue to benefit from such rights. However, individuals who are in possession of a permit issued under the Residents Scheme should note that:

• Residents Scheme permit holders must be in receipt of stable and regular resources which are sufficient to maintain the permit holder and his/her dependents without recourse to the social welfare system in Malta
• The permit holder and his family must be covered by a health/medical insurance
• If the permit holder sells his Maltese property (the property that was acquired pursuant to the Residents Scheme), he will be required a property at the applicable HNWIs Scheme thresholds in order to retain his residence permit
• An individual who is currently in possession of a Residents Scheme certificate may relinquish the benefits under such scheme and apply for a tax status in terms of the new HNWI Schemes. 

Pending applications under the Residents Scheme

An individual who applied for a certificate in terms of the Residents Scheme but whose application was not processed as a result of the suspension of the scheme in December 2010 may apply in terms of the HNWI Schemes and will be subject to the HNWIs Schemes eligibility criteria. However, applicants will be deemed to hold a Qualifying Property Holding for the purposes of the HNWIs Schemes if they-
• purchased property before 14 September 2011 for a consideration of not less than €116,000 or
• entered into a promise of sale agreement before the 14th September 2011 to buy such property provided that the property is purchased by not later than the 31 March 2012 or
• entered into a lease agreement prior to 14 September 2011 for an amount of not less than €4150 per annum
In all cases the property must be occupied by the individual and his family (where applicable) as the primary residence worldwide

Official fee

A non-refundable administrative fee as of €6,000 is payable to the Maltese tax authorities at the time of submitting an application in terms of the HNWI Scheme.

This fee is waived in the case of applications submitted by individuals who had previously applied under the old Residents Scheme Regulations (which was suspended in December 2010) and which application was duly received and acknowledged by the Commissioner of Inland Revenue before 14th September 2011. Such waiver is subject to presentation of a copy of the acknowledgement together with the application. This exemption will apply until the 15th of September 2012.

Our services

An application for special tax status under the HNWI Rules may only be submitted to the Commissioner of Inland Revenue through the services of an Authorised Registered Mandatory (ARM). We can assist prospective individuals and their family by providing a full range of services in connection with their application under the HNWI Schemes and their relocation to Malta. We also provide legal and tax advice and support throughout their stay in Malta.

For further information about the HNWIs Scheme and about how can we be of help, please contact This e-mail address is being protected from spambots. You need JavaScript enabled to view it or This e-mail address is being protected from spambots. You need JavaScript enabled to view it .