Malta has introduced the Individual Tax Programme (ITP), a new framework that will come into force on 1 January 2027. The programme consolidates a number of existing special tax residence regimes, including the Global Residence Programme (GRP) and the Malta Retirement Programme (MRP), into a single legislative framework with four categories of special tax status. Eligible beneficiaries will continue to benefit from a 15% tax rate on foreign-source income remitted to Malta, subject to qualifying conditions and applicable minimum tax thresholds.
Key Changes Under the New Programme
• One unified framework: The ITP replaces several existing residence-based tax programmes with a single set of rules and four categories of special tax status.
• Five-year renewable status: New approvals will be granted for a period of five years and may be renewed for further five-year periods.
• Updated property thresholds: Applicants will be required to own residential property valued at a minimum of €700,000 or lease property with a minimum annual rent of €14,000.
• Higher minimum tax obligations: Beneficiaries under the Global Resident Status and EU/EEA/Swiss Resident Status categories will be subject to a minimum annual tax liability of €35,000, while pensioners qualifying under the Retired Pensioner Status category will be subject to a minimum annual tax liability of €15,000.
Impact on Current GRP and MRP Beneficiaries
The most important takeaway for existing clients is continuity and legal certainty. The new rules expressly provide that beneficiaries who have already obtained special tax status, or who submit an application by 31 December 2026, will retain their status until 31 December 2031. As a result, current GRP and MRP beneficiaries will not be required to transition immediately to the new regime and may continue benefiting from their existing status during the transitional period.
For prospective applicants, however, the ITP will become the sole route to obtaining special tax status from 1 January 2027, bringing with it revised eligibility criteria, enhanced compliance requirements, and updated minimum tax and property thresholds.
Early planning is key. Speak with our advisors today to prepare for Malta’s tax residence framework.