Maltese Residence

Malta Tax Domicile

The Malta Tax Domicile of an individual is the most persistent tax connection recognised in Maltese tax law and is acquired from one’s father at birth or after reaching the age of 18 by choice. Losing one’s Malta tax domicile cannot happen without intent, action and strong resolve.  Likewise, for a foreign non-dom person to acquiring tax domiciled status in Malta requires significant planning and implementation.

Malta Tax Domicile: Domicile of Origin

A person acquires tax domicile of origin at birth automatically from the father.  Children born out of wedlock or losing their father, automatically adopt the domicile of their mother. Where the country of birth is different from the country of the father’s domicile, the father’s domicile prevails as the domicile of birth of that individual.

The strength of the domicile of origin is demonstrated by the automatic revival of this domicile upon abandoning the domicile of choice without the acquisition of a new one.  The tax domicile of origin remains relevant throughout the life of the person as domicile retains its capacity for revival.

Malta Tax Domicile: Tax Domicile of Choice

It is very difficult to renounce the domicile of origin. Only upon reaching majority can a person exercise legal capacity to adopt a new domicile – a domicile of choice.  However, the burden of proof of the acquisition of a tax domicile of choice falls upon the taxpayer claiming this change in tax domicile.

To lose one’s domicile of origin one must acquire a domicile of choice. It is not sufficient to leave the country of domicile of origin permanently without clear evidence that the individual has no intention whatsoever to return to the country of his domicile of origin.  In order to do so one must be able to prove that:

  • He is resident in the new country.
  • He intends to reside there permanently or for an unlimited time.

One must be physically present in a country in order to acquire the domicile of choice. One must also consider criteria such as the individual’s business and family interests in the new country of domicile, the ownership of any property there and any remaining ties with other countries.

Malta Tax Domicile: Tax Domicile by Operation of Law

To establish a definite legal system by which certain rights and obligations may be governed, the objective of the law is that no person shall be without a domicile. This is crucial today, especially because free movement has given not only rights to individuals but also obligations and in the interest of liability, it is necessary to hold that a person cannot posses more than one domicile at the same time.

Given the importance of having a domicile, in situations where one cannot establish the domicile of origin and is unable to make a choice, the law intervenes. The third kind of domicile is the domicile of dependence and it arises by operation of law.

The Domicile of Dependence

It is a domicile in which the law establishes a person’s domicile, such as in the case of a foundling, where the law provides that a foundling acquires the domicile of the country where he is found.

It has been held that as the domicile of origin requires the child to take the domicile of the father at birth, in the case where either the child’s father is dead or the child is illegitimate, the child acquires the domicile of the mother.

Until one has the legal capacity to adopt a domicile of choice, his domicile of origin will be replaced by domicile of dependence should the person on whom he is legally dependent adopt a domicile of choice elsewhere. This means that until a person reaches adulthood his domicile will shift according to the domicile of the person on whom he is dependent. Women take up their husband’s domicile upon marriage and such domicile is maintained even if they are legally separated or if the husband passes away (Attard, 2005).

Non Dom Status for Malta Residents

Foreigners considering taking up residence in Malta under whichever Malta immigration programme or any Maltese special tax programme, will oftentimes enjoy the benefit of non-dom status. Non doms who are resident in Malta are not subject to tax on their worldwide income and instead are subject to tax on income arising in Malta.  Residence can be acquired under the special tax status programme the Malta Global Residence Programme requiring a yearly minimum tax payment of merely €15,000 and an upfront investment of only €6,500.   Alternatively, one can acquire Permanent Residence for life for all the family under the Maltese Permanent Residence Programme by buying or renting a property in Malta.

Malta Tax Domicile Planning

Losing, acquiring or reviving tax domicile requires expert planning by experienced tax lawyers.  For an expert tax consultation on Maltese tax domicile and residence planning, book a meeting with one of our tax lawyers. With over 20 years advising on Maltese personal and corporate tax matters, we look forward to assisting you with planning your relocation, residence or tax domicile in Malta.

Malta Permanent Residence Programme announced

Residence Applications

Malta Global Residence Programme


Malta Global Residence Programme

Since 2013, the Malta Global Residence Programme builds on the success of Malta’s reputation in attracting expatriates seeking an alternative residence base in a warm Mediterranean Island in the European Union.

Basis for Malta Global Residence Status

The aim of the Malta Global Residence Programme is to formally recognise as tax resident for Maltese tax purposes those foreign nationals satisfying the eligibility criteria of the Malta Global Residence Programme.  The Maltese Residence Programme requires that an economically self-sufficient residence candidate maintains a permanent address in Malta in the form of residential property purchased or rented in Malta or Gozo.

Taxation of Maltese Global Residents

Maltese residents are not subject to tax in Malta on foreign sourced income not remitted to Malta. Nor are they subject to tax on any foreign-sourced capital gains whether remitted to Malta or not.  Permanent Residents of Malta are entitled to taxation at the flat rate of 15% on remitted income.

Malta enjoys over 60 double tax treaties, persons who take up residence in Malta can receive their pensions in Malta free of tax at source and subject to a mere 15%.  Global residents also benefit from Malta’s double taxation agreements existing with most European countries, Canada, Australia and the USA, ensuring that tax is never paid twice upon the same income.  Overseas capital funds invested locally are of course only taxed on any interest or dividends generated thereon, again at a 15% flat rate.

For EU and EEA nationals, in the absence of significant remittances of income, it may be more feasible to opt for the Ordinary Residence Scheme which imposes no minimum tax liability.

The following is a summary of the tax system applicable to Maltese residence under this residence programme.


Summary of Malta Global Residence Tax Rules

Basis of Taxation Local Source, Remittance
Tax Rate for Foreign Source Income remitted to Malta 15%
Tax on Capital Gains outside Malta Nil
Tax Rate for Local Personal, Business, Investment Income 35%
Minimum tax (per family) €15,000
Taxation per dependent Nil
Double Tax Treaty Relief applicable
Taxation per dependent Nil
Tax Residence Certificate Process available.
Inheritance Tax None

Eligibility for Maltese Global Residence Programme

Applications under the Malta Global Residence Programme are open to non-EU, non-EEA and non-Swiss nationals.  One application can include the main applicant as his spouse, financially dependent ascendants and other non-family members and dependent relatives that are shown to be bona fide members of the household.  Children under the age of 25 are automatically eligible for inclusion.  Applicants must demonstrate their financial self-sufficiency and must be in possession of valid sickness insurance cover.

Within 12 months of taking up residence under the Malta Global Residence Programme, the residence permit holder needs to comply with the requirement of acquiring or renting property in Malta.  Residence candidates are required to demonstrate that an address is available to them in Malta by buying or renting property in Malta.  Candidates for the residence programme need to meet minimum property value requirements at €275,000 for property in Malta and €220,000 for property in Gozo and the Southern Region of Malta.  Candidates have the option to rent property in Malta at €9,600 or property in Gozo and the Southern Region of Malta at €8,750 in annual rent.

The following is a summary of the programmes rules on eligibility of applicants.


Summary of Malta Global Residence Programme

Eligible for inclusion in application:
Main Applicant’s spouse Yes
Dependants < 25 years
Non-Family Members Discretionary
Taxation per dependent Nil
Minimum Property Purchase Price / Annual Rent
 Malta: €275,000 / €9,600
Southern Region of Malta, Gozo €220,000 / €8,750
Sickness Insurance Coverage Required



Malta Global Residence Programme: The Rules

Permit holders are required to reside not more than 183 days in any foreign jurisdiction in any year. The programme does not impose any formalities for evidencing any minimum residence requirement.  Residents also need to demonstrate a valid sickness insurance coverage for all EU risks including Malta.

Malta Global Residence Programme Permits are issued subject to the following conditions:

Residence Permit Conditions

Maltese domicile Not allowed
Maximum Residence in other countries < 183 days
Employment, Business, Office in Malta allowed

Malta Global Residence Programme Applications

Applications are to be processed via Mandataries authorised by the Maltese Government to handle application process and act as liaisons between the applicant and the Maltese authorities.  Our immigration firm is registered as an authorised mandatary by the Maltese immigration and tax authorities according to Maltese law.  Led by Dr Priscilla Mifsud Parker, our winning Immigration & Relocation Law team is the oldest specialised immigration law practice in Malta. We have successfully represented individuals and families ranging from expatriate retirees, emigrants seeking employment, applicants for work permits, to HNW individuals on the Forbes List.

We are able to advise you on the tax and legal implications and requirements of the Malta residence application process and indicate expected time frames based on the specific circumstances and nature of your application. Our advice covers the rules applicable to immigrating to Malta under a number of available residence programmes as well as practical relocation assistance ranging from transportation and insurance to schooling and health insurance coverage.

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Malta Permanent Residence Programme

The Malta Permanent Residence Programme, launched in 2021 by means of Legal Notice 121 of 2021, offers permanent residence in Malta upon successful completion of a four-tier due diligence process.

Malta Permanent Residence Programme MPRP

Residency cards are issued for 5 years and are renewable indefinitely provided the investor maintains a Maltese address and all other Programme requirements and eligibility. The MPRP is based on either a property investment or on the rental of property, together with the payment of a contribution to the government and a donation to charity. Processing takes between 4 to 6 months.

Malta Permanent Residence Programme: Benefits

  • Maltese Permanent Residence grants families the right to reside and stay indefinitely in Malta: a Certificate of Malta Permanent Residence for Life is issued after approval upon complying with the investment requirements.
  • Malta is part of the Schengen Area and investors enjoy visa-free movement within the Schengen Area, with no visa applications required prior to travel and freedom of movement within the 26 countries that form the Schengen Zone for 90 days out of a 180-day period.
  • The Malta Permanent Residence Programme allows its beneficiaries the right to reside, settle and stay in Malta indefinitely.

Learn more about the benefits of the Malta Permanent Residence Programme.

Malta Permanent Residence vs Other Golden Visas

Malta continues to take note of a competitive marketplace of European countries competing in their attractiveness for foreign investors. Accordingly, some competitive advantages:
  • The Malta Permanent Residence Programme is the only European residency program to allow a property rental option without requiring the purchase of property before applying for residence, making the process both easy and convenient in times when travel restrictions are the norm.
  • The required investment need only be made on approval at the end of the process and not at the outset.
  • Permanent residence is indefinite as long as all Programme obligations are maintained..
  • Property ownership is not obligatory since a rental option is available.
  • Residence cards are renewed every 5 years.
  • English is an official language and is widely spoken in Malta. However, the Malta Permanent Residence Programme does not apply a language test at any stage.

Eligibility for Malta Permanent Residence

In order to be eligible for the programme, the applicant must show that he is in possession of €500,000 in capital, of which €150,000 must take the form of financial assets, such as bank deposits or stocks.

Family applications are allowed by the Malta Permanent Residence Programme.  The following family members may be included in a family application for Maltese permanent residence:

  • spouses or unmarried long term partners;
  • dependent unmarried children with no age limit, as well as
  • parents and grand parents on either side

More about Eligibility and Requirements for the Malta Permanent Residence Programme in our MPRP FAQ section

Investments Qualifying for Malta Permanent Residence

Subject to a non-refundable government administration fee of €10,000 payable on submission of the PR application, all investments and the government contribution are payable only on approval. The Malta government contribution is lower if the applicant chooses to buy rather than rent a qualifying property.

The Property Investment Option

Permanent Residence under the Malta Permanent Residence Programme requires a fixed government contribution of €68,000 together with a minimum residential property investment in Malta of at least €300,000 in Gozo or the South of Malta, or at least €350,000 in the rest of Malta.

The Property Rental Option

Property ownership is not obligatory, and applicants may opt to rent rather than purchase property in Malta – this attracts a higher non-refundable government contribution of €98,000. The minimum qualifying rent for property in the south of Malta is €10,000 and €12,000 in the rest of Malta.

Hence, an applicant must:

  1. Choose a property investment (rental or purchase)
  2. Pay a contribution of €68,000 when purchasing or €98,000 when renting a property
  3. Pay a €2,000 donation to an approved charity or NGO.

Malta Permanent Residence: Time Frame

From the Agency’s side, there is a renewed commitment towards increased efficiency, with a targeted processing time of 4-6 months, leaving due diligence of applicants as paramount over speed considerations.

Malta Permanent Residence: Contributions

The fees under the new MPRP regulations are as follows:

  • €68,000 / €98,000 government contribution (in case of property purchase/rental respectively).
  • Parents/grandparents: €7,500

A philanthropic donation of €2,000 to an approved charity or NGO in Malta is also to be paid after the approval.

Competitiveness of Maltese PR

Malta continues to take note of a competitive market place of European countries competing in their attractiveness for foreign investors. Accordingly, some competitive advantages:

  • Permanent residence status is not lost if the resident does not reside in Malta in any given year.
  • No need to purchase property if property rent is preferred to start with.
  • Persons planning their tax resident status in Malta should seek tax advice on the minimum presence and other criteria required for tax residence.

Tax System for Malta Permanent Residents

The Malta Permanent Residence Programme is tax neutral and does not offer any tax benefits, nor does it create any adverse tax effects. Malta’s tax system applies independently of the MPRP.

Tax resident status is not an automatic consequence of acquiring permanent residence in Malta.

Tax Resident Status

Tax resident status results from a residence in Malta of over 183 days, or where residents have spent less than the 183 days in Malta, they may demonstrate various connecting factors evidencing their intention to reside in Malta ordinarily. Permanent residents of Malta requiring formal confirmation of their tax residence status in Malta are able to obtain this through a separate procedure – prior legal advice is recommended. Contact us for a tax consultation.

Non Tax Residents

Non-tax residents are only subject to tax on local source income. Tax residents of Malta enjoy a remittance basis of taxation, often referred to as res non-dom taxation, whereby they are only subject to Maltese tax on their foreign income only to the extent remitted to Malta, and not on their foreign source capital gains, whether remitted or not. The enjoyment of the res non-dom tax regime by persons having incomes sources abroad exceeding €35,000 are subject to a minimum annual tax of €5,000.

Under Maltese law, the connecting factors determining the taxability of individuals are domicile and residence, remnants of Malta’s British colonial history. Citizenship is not a factor that effects the taxation of individuals.

Income is taxable in Malta only if it arises in Malta. Income arising abroad, is only taxable in Malta if a person is tax resident in Malta and only on that portion that is remitted to Malta. Capital gains are taxable in Malta only if arising in Malta but are subject to various exemptions. Capital gains arising out of Malta are not subject to tax, nor are they reportable, whether remitted to Malta or not.
Malta has no wealth or capital taxes, no wealth reporting obligations, no inheritance taxation, no property taxes, no dividend taxes, and no system of rates.

Learn more about personal taxation of Maltese Residents

Our Malta Permanent Residence Services

ACC is a Maltese Immigration Firm holding licence number AKM-ACCA-22. We guide high net worth international families and their businesses on subjects as diverse as residency & citizenship, corporate, tax, financial services, fintech, property.  Over the last 20 years, our Malta Permanent Residence specialists have successfully represented hundreds of individuals and families ranging from expatriate retirees, emigrants seeking employment. We are committed to promoting Malta as a welcoming investment and relocation destination, with a history of hospitality and multi-culturalism.

We are able to advise you on the tax and legal implications and requirements of the residence application process and indicate expected time frames based on the specific circumstances and nature of your application. Our advice covers the rules applicable to immigrating to Malta under a number of available residence schemes as well as practical relocation assistance ranging from transportation and insurance to schooling and health insurance coverage.


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Residency Options

European Union Nationals

The Residents Scheme Regulations were enforced in 2004 and outlined the certain criteria individuals must comply with in order to be eligible to take up residence in Malta.

A certificate must be obtained from the Inland Revenue Department to allow residency. This certificate is valid indefinitely as long as the individual fulfils certain conditions annually. It typically takes three months from the date of application to issue the certificate. The minimum sum of tax is to be paid within thirty days of the application’s approval. It is to be credited against the taxation payable for the first year of residence.

Individuals must fall into at least one of the three categories below in order to be eligible to obtain residency in Malta.

  • Employed: To obtain ordinary residence an individual must work in Malta either as an employee or self-employed.
  • Economically self-sufficient: Individuals applying for ordinary residence must prove to be financially stable. They must have a minimum capital of €14,000 or a weekly earning of €92.32 is required for single individuals and a minimum capital for married couples is €23,300 or €108.63 per week.
  • Own worldwide capital: Must own worldwide capital amounting to a minimum of €349,000. It is also required that the individual remit at least €13,950 to Malta per year, in addition to €2,300 for each spouse or dependant. A holder of a Residents Scheme document is obliged to buy or lease a property in Malta. The minimum worth of apartments is €69,000 and of houses €116,000. In the case of leasing, the minimum monthly rent must be €4,150.

Third Country Nationals

Individuals must fall into at least one of the two categories below in order to be eligible to obtain residency in Malta.

Employed: An employment license is necessary for non-EU citizens to work in Malta. Individuals who are qualified in information technology or financial services are favoured over other occupations and consequently may receive a permit more easily.

Self-Employed: To be certified as self-employed or a business owner, a third country national must meet specific criteria.

  1. An individual must have invested a minimum of €500,000. Expenditure on the investment should be solely capital, and should include fixed assets (property, machinery) used for the occupation and should be representative of the business plan proposed upon application. Extra expenses including legal fees and wages must not be paid via the initial invested sum of €100,000.
  2. An individual must qualify as a gifted innovator and propose an attractive business plan. This plan must include employing a minimum of three EU citizens within eighteen months of the business being founded.
  3. An individual must hold a high ranking position in a company that forms part of a project that is advocated by Malta Enterprise and which the Employment and Training Corporation (ETC) has knowledge of; or
  4. An individual must hold the title of exclusive representative of a foreign company that aims to set up a new branch in Malta.