The above rules recently published in terms of Legal Notice 20 of 2026 and effective from 1st January 2026, introduce a consolidated set of rules applicable to non-domiciled highly skilled individuals holding an eligible office and who hold a qualifying contract of employment for relevant employment activity in the following sectors:
“Financial services/Gaming/Transport/Aviation/Maritime and Shipping/ Offshore oil and gas sectors/Science/Engineering sectors/ Family offices/Treasury Management”
The special tax rate of 15% (if opted for) would apply to qualified professionals holding requisite qualifications and at least 5 years’ experience, earning a deemed minimum of €65,000 (increasing by €10,000 per annum) and a maximum €7,000,000 from the respective qualifying employment carried out in Malta. Beneficiaries may benefit from the special tax rate for 5 years once formal determination is issued which may be extended for an additional two periods.
Applications may be made between 1st January 2026 until 31st December 2035 and no further applications may be accepted after 31st December 2036.
Special transitional rules apply to individuals, who on the 31st December 2025, who already qualified under the following Rules:
- Highly Qualified Persons Rules;
- Qualifying Employment in Innovation and Creativity (Personal Tax) Rules;
- Qualifying Employment in Aviation (Personal Tax) Rules;
- Qualifying Employment in Maritime Activities and the Servicing of Offshore Oil and Gas Industry Activities (Personal Tax) Rules or
- Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules.
No new determinations under these rules will be made and no further benefits may be availed of after year of assessment 2030. However, beneficiaries have the option to migrate to the new rules through the submission of an application to relevant authorities by the 31st of December 2028.
Do reach out to us for further insights and information regarding the above rules and if you require any assistance in the application process and/or transition to the new rules.
