Malta Tax Residency Rules
Malta distinguishes ordinary residence (183+ days) from habitual residence (accommodation available year-round). Non-domiciled residents pay tax only on Malta-source income and foreign income remitted to Malta. The Global Residence Programme provides a structured path for non-EU/EEA nationals with a minimum €15,000 annual tax. No capital gains tax on securities; no inheritance or wealth tax.
| Ordinary residence | 183 days in the calendar year |
| Habitual residence | Accommodation available in Malta throughout the year — no day-count required |
| Rule type | Dual test — ordinary residence + habitual residence |
| Complexity | Medium — non-dom remittance basis available |
| Tax year | Jan 1 – Dec 31 |
| Special regimes | Global Residence Programme (GRP) · Highly Qualified Persons rules (15% flat rate) · Non-dom remittance basis |
| Capital gains | No CGT on securities transfers. Property transfers subject to final withholding tax |
| Inheritance tax | None (abolished 1977) |
| Schengen area | Yes |
| Official source | Commissioner for Revenue (CFR) ↗ |
Ordinary vs habitual residence
Maltese tax law distinguishes two residency concepts. Both result in Maltese tax residency, but they trigger at different points:
A person is ordinarily resident in Malta in a calendar year if they are physically present in Malta for 183 or more days during that year (January 1 to December 31). Days of arrival and departure both count. This is the standard threshold — analogous to the 183-day rules in Spain, Portugal, and Italy.
A person is habitually resident in Malta if they have accommodation available in Malta throughout the calendar year — owned or rented — and there are circumstances indicating an intention to reside in Malta habitually. The key distinction from ordinary residence: no day-count minimum. Someone who rents a Maltese apartment year-round but spends only 60 days there per year may be considered habitually resident.
The accommodation test mirrors Portugal's habitual home rule. The Maltese Commissioner for Revenue (CFR) assesses the availability of the accommodation and surrounding circumstances — whether the property is rented out commercially, whether it is furnished for personal use, and whether other life indicators suggest Malta as a habitual base.
Non-domicile and remittance basis
Malta retains a remittance basis for residents who are not Maltese domiciled. For most relocating foreigners, this is the default position — domicile under Maltese law follows common-law principles (domicile of origin; domicile of choice requires genuine abandonment of prior domicile and permanent settlement in Malta).
A person who is Malta tax resident (ordinary or habitual) but not Maltese domiciled is taxed on:
- Malta-source income — in full, regardless of remittance
- Foreign income remitted to Malta — taxed when brought into a Maltese bank account or used in Malta
- Foreign income not remitted — not subject to Maltese tax
- Capital gains from non-Maltese sources — not taxable in Malta, even if remitted (capital gains are outside the remittance basis charge under current Maltese law)
The practical benefit for high earners: foreign-source income kept outside Malta (in accounts in other jurisdictions) accumulates free of Maltese tax. This makes Malta structurally attractive for passive income earners and investors managing offshore portfolios.
Global Residence Programme (GRP)
The GRP is a formal, government-administered tax residence programme for non-EU, non-EEA, and non-Swiss nationals. It provides a structured tax framework for relocating to Malta without conventional employment.
GRP residents pay a flat 15% on foreign income remitted to Malta, subject to a minimum annual tax of €15,000. Income not remitted to Malta is not taxed. There is no Maltese tax on capital gains from non-Maltese sources (remitted or not).
GRP applicants must hold qualifying Maltese property:
- Purchase: minimum €275,000 (or €220,000 in southern Malta / Gozo)
- Rental: minimum €9,600 per year (or €8,750 in southern Malta / Gozo)
The property must serve exclusively as the applicant's principal residence — subletting is not permitted.
- Must not be resident in any other jurisdiction
- Must hold comprehensive health insurance covering the EU
- Must not carry out any professional activity in Malta (passive income / overseas employment only)
- A one-time administrative fee of €6,000 is payable (€5,500 for properties in southern Malta / Gozo)
EU nationals do not need the GRP. EU, EEA, and Swiss citizens can establish Maltese tax residence under the ordinary rules (183-day or habitual residence) without the GRP framework. The GRP specifically provides a pathway — and the associated tax certainty — for citizens from outside the EU/EEA/Switzerland.
Highly Qualified Persons rules
Malta offers a 15% flat tax rate on employment income for qualifying individuals working in specific industries in Malta. The Highly Qualified Persons (HQP) rules cover roles in financial services, remote gaming, and aviation.
- Minimum qualifying income: €87,947 per year (rate reviewed annually)
- The 15% rate applies to qualifying employment income for up to 4 years (extendable in some cases)
- Income below the qualifying income threshold is taxed at normal progressive rates
- Employment must be with a recognised Maltese licence holder in an eligible sector
What there is no tax on
Malta's tax framework lacks several levies common in northern European countries:
- No capital gains tax on securities. Transfers of shares, bonds, units in funds — not subject to Maltese CGT. This is a consistent, long-standing feature of Maltese tax law, not a temporary relief.
- No inheritance or estate tax. Abolished in 1977. Property passing on death is subject to duty at 5%, not an estate tax.
- No annual wealth tax. No levy on the value of personal assets.
- No withholding tax on dividends paid to non-resident shareholders in most circumstances (subject to treaty provisions).
Track your days in Malta
Monitor your presence against the 183-day ordinary residence threshold.
Frequently asked questions
What is the tax residency threshold in Malta?
183 days in the calendar year for ordinary residence. Habitual residence — triggered by having accommodation available in Malta year-round — can establish residency without any day-count minimum. Both ordinary and habitual residents are taxable on Malta-source income and foreign income remitted to Malta (if not Maltese domiciled).
What is the Global Residence Programme?
A formal tax residency programme for non-EU/EEA/Swiss nationals. GRP residents pay 15% on foreign income remitted to Malta, with a minimum annual tax of €15,000. Requires qualifying Maltese property (€275,000 minimum purchase or €9,600 minimum annual rent) used exclusively as principal residence.
Is there capital gains tax in Malta?
No CGT on transfers of securities (shares, bonds, collective investment scheme units). Property in Malta is subject to a final withholding tax (not CGT) on transfers. Foreign-source capital gains are not taxable in Malta for non-domiciled residents, whether remitted or not.
Can I avoid Maltese tax on foreign investment income by not remitting it to Malta?
For non-Maltese domiciled residents, yes — foreign income not remitted to Malta is not subject to Maltese tax. Capital gains from non-Maltese sources are also not taxable regardless of remittance. This is the remittance basis that Malta maintains for non-dom residents. The position for Maltese domiciled individuals (rare among recent relocators) is different — worldwide income is taxable.
Do I need to spend a minimum number of days in Malta under the GRP?
The GRP does not set a minimum annual days requirement explicitly. However, GRP participants must maintain qualifying Maltese property as their principal residence, must not be resident in another jurisdiction, and must demonstrate genuine Maltese tax residence. In practice, this requires spending meaningful time in Malta — typically at least several months — to substantiate the claim of principal residence.
Is Malta in Schengen?
Yes. Malta joined the Schengen area in 2007. Non-EU/EEA nationals must track their Schengen 90/180-day allowance separately from Maltese tax residency thresholds. Holding a Maltese residency permit (under the GRP or other schemes) removes the Schengen day-count restriction.
Related guides and tools
Tracking Malta alongside other countries?
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This page is for informational purposes only and does not constitute tax or legal advice. Maltese tax residency rules, the GRP, and the non-domicile regime involve specific administrative and legal requirements not fully covered here. The HQP qualifying income threshold is reviewed annually. Consult a qualified Maltese tax adviser or the Commissioner for Revenue for your specific situation.