Introduction

Background

On the 14th of July 2026, the Individual Tax Programme Rules 2026 (the "Rules") were published by means of Legal Notice 195 of 2026, consolidating the special tax status programmes currently in force into one framework, set to come into force with effect from the 1st of January 2027,

The Rules harmonise the special tax status programmes currently in force, the Global Residence Programme, the Malta Residence Programme, the Malta Retirement Programme, and the United Nations Pensions Programme, into a single, unified framework.

By replacing four separate sets of rules with one, the reform is intended to simplify how special tax status is applied for and administered, while carrying forward the core features that have long distinguished each programme.

The Four Categories of Special Tax Status

The Rules establish four categories of Special Tax Status, each replacing an existing programme:

  • Global Resident Status: replaces the Special Tax Status previously granted under the Global Residence Programme.
  • EU, EEA, Swiss Resident Status: replaces the Special Tax Status previously granted under the Malta Residence Programme.
  • Retired Pensioner Status: replaces the Special Tax Status previously granted under the Malta Retirement Programme.
  • UN Pensioner Status: replaces the Special Tax Status previously granted under the United Nations Pensions Programme.

Eligibility

To be eligible, an applicant must

  • Hold a qualifying property in Malta;
  • Meet the general eligibility criteria for all Special Tax Status categories; and
  • Meet the category-specific eligibility criteria for their particular Special Tax Status category.

Qualifying Property in Malta

A Qualifying Property is defined as either:

  • a Qualifying Owned Property; or
  • a Qualifying Rented Property;

which is occupied by the Beneficiary as his primary residence.

Qualifying Owned Property

A Qualifying Owned Property is defined as an immoveable property purchased for at least EUR700,000.

Qualifying Rented Property

A Qualifying Rented Property is defined as an immoveable property taken on lease of not less than EUR14,000 per year.

Restriction on Sub-Letting

Only the Beneficiary, his dependents or household staff may reside in the Qualifying Property.

General Eligibility Criteria

Across all categories, the applicant must:

  • Be in receipt of stable and regular resources sufficient to maintain himself and his dependents in Malta without recourse to the social assistance system;
  • Hold a valid travel document;
  • Hold sickness insurance in respect of all risks across the whole of the EU normally covered for Maltese nationals, for himself and his dependents;
  • Not be domiciled in Malta and does not intend, within 5 years from the date of application, to establish his domicile in Malta;
  • Adequately communicate in English or Maltese;
  • Be a fit and proper person; and
  • Not benefit under any other special tax status in Malta;
  • Not reside in any other jurisdiction for more than 183 days in a calendar year.

Category-Specific Eligibility Criteria

Global Resident Status

The applicant must also:

  • be a third-country national (not an EU, EEA or Swiss resident).
  • not hold, or have applied for, long-term resident status in Malta.

EU, EEA, Swiss Resident Status

The applicant must also:

  • be an EU, EEA or Swiss resident;
  • not be a Maltese national or permanent resident of Malta.

Retired Pensioner Status

The applicant must also:

  • not be a Maltese national, long-term resident or permanent resident of Malta.
  • be in receipt of a pension, all of which is received in Malta and such pension constitutes at least 75% of his chargeable income.

UN Pensioner Status

The applicant must also:

  • not be a Maltese national, long-term resident or permanent resident of Malta.
  • be in receipt of a UN Pension, Widow’s Benefit or Widower’s Benefit, of which at least 40% is received in Malta.

Special Tax Status

Applicants granted Special Tax Status (hereinafter the ‘Beneficiary’) shall be subject to tax as follows:

Income Arising Outside Malta and Received in Malta

A flat rate of 15% applies to income arising outside Malta which is received in Malta by the Beneficiary, the Beneficiary's spouse, minor children, and children unable to maintain themselves due to illness or disability.

This is subject to a minimum annual tax of:

  • EUR35,000 for Global Residence Status;
  • EUR35,000 for EU, EEA or Swiss Residence Status;
  • EUR15,000 for Retired Pensioner Status.
  • EUR20,000 for UN Pensioner Status.

UN Pensioner Status: Exemption on UN Pension

A UN Pensioner is exempt from income tax on their UN pension, Widow's Benefit, or Widower's Benefit. All other income arising outside Malta and received in Malta remains subject to the flat 15% rate, subject to the minimum annual tax specified above.

Income Arising in Malta

Income arising in Malta shall be subject to income tax at a flat rate of 35%.

Dependents

Definition

The Rules define a dependent as any of the following persons who reside with the Beneficiary in the Qualifying Property:

  • The Beneficiary's spouse, or a person with whom the Beneficiary is in a stable and durable relationship;
  • Minor children, including children in the care and custody of the Beneficiary or spouse;
  • Children under the age of 25, provided they are not economically active; and
  • Children who are not minors but who, because of illness or disability of serious gravity, are unable to maintain themselves.

Transfer of Special Tax Status on Death of Beneficiary

Upon the death of the Beneficiary, Special Tax Status may be granted to a dependent who:

  • inherits the property listed as the primary residence of the deceased Beneficiary; and/or
  • immediately rents a Qualifying Rented Property following the Beneficiary's death,

provided that the dependent meets the general eligibility requirements.

Applications

Requirement of an Authorised Registered Mandatory

Applications for special tax status under the Rules must be made through an authorised registered mandatory.

The Application Fee

Each application must be accompanied by a non-refundable administration fee of EUR 8,500.

Duration & Renewals

Annual Renewals: Minimum Tax Payment & Compliance Returns

The minimum tax must be paid by the 30th of April of each year. Proof of payment must be submitted to the Commissioner, together with a Return confirming continued compliance with the eligibility criteria.

Five-Year Term & Renewals

The Special Tax Status shall apply for a term of five (5) years, provided the annual renewals are filed.

A Beneficiary may then apply to renew for further periods of five years against a non-refundable administrative fee of EUR 2,500. The Rules provide that a renewal application may not be unreasonably withheld.

Ongoing Obligations

Annual Returns

An annual Return confirming compliance with the eligibility criteria is to be submitted.

Annual Confirmations re-Long-Term/Permanent Residents

Each year, the authorised registered mandatory must enquire and obtain information as to whether the Beneficiary or any of his dependents have obtained long-term or permanent resident status in Malta.

  • If so, the Commissioner must be notified by 30 April.
  • If the information cannot be obtained, the Commissioner must be notified by 30 April, evidencing at least two attempts at enquiry.

Failure to comply results in a penalty of EUR 10,000.

Change in Special Tax Status

Where an individual no longer meets the eligibility criteria and consequently loses his Special Tax Status, he must notify the Commissioner through his authorised registered mandatory within four weeks. Failure to do so results in a penalty of EUR 5,000. The Minister retains the discretion to pardon a failure where it was due to unforeseen circumstances, where the individual notifies the Minister of the failure, or where the individual exercises his best efforts to remedy it.

Change in Dependents

Beneficiaries, through their authorised registered mandatory, must notify the Commissioner of any change in dependents within four weeks of the date of change. Failure to do so results in a penalty of EUR 5,000.

Previously Acquired Special Tax Status

Persons who acquired Special Tax Status prior to the 1st of January 2027, as well as any persons who filed an application for Special Tax Status prior to that date, shall continue to benefit from such status until the 31st of December 2031.

Conclusion

The Individual Tax Programme Rules 2026 represent a significant step in the ongoing modernisation of Malta's approach to special tax status. By consolidating four established programmes into a single, coherent framework, the Rules aim to simplify the application process and provide greater clarity for internationally mobile individuals and retirees considering Malta as their base, while preserving the distinct eligibility conditions and tax treatment that characterise each category.

With the Rules coming into force on 1 January 2027, and a transitional window running to 31 December 2031 for those already holding or applying for status under the outgoing programmes, individuals and their advisers should begin assessing their position now. Whether an application is best pursued under the existing programmes ahead of the transition, or under the new framework, will depend on the individual's residence profile, income sources, and long-term plans. Given the strict eligibility criteria, ongoing compliance obligations, and the requirement to apply through an authorised registered mandatory, professional guidance is essential to navigating the regime effectively.

Contact Us Today

zeta. is an authorised registered mandatory and can assist individuals and families in assessing their eligibility for Special Tax Status, preparing and submitting applications, and managing the annual compliance obligations that follow.

 To discuss how the Individual Tax Programme Rules 2026 may affect your position, or to explore whether one of the four categories fits your profile, speak to our team:

Telephone: +356 20119700

Email: info@zeta-financial.com