The United Nations Pensions Programme (UNPP)

Introduction

The United Nations Pensions Programme (UNPP) is regulated under the United Nations Pensions Programme Rules, which came into force in 2015 and were subsequently amended in 2020. Under the United Nations Pensions Programme (UNPP), all United Nations retirees (other than Maltese nationals) may apply for residence in Malta together with a Special Tax Status.

Benefits

Upon receiving Special Tax Status in Malta, the beneficiary will be granted the right to reside in Malta and will be taxed in Malta as follows:

– UN Pension/Widow’s Benefit income: 0% (exempt from income tax in Malta);

– Foreign-Sourced Income Remitted to Malta: 15% (subject to a minimum tax of €10,000 per annum);

– Malta-Sourced Income: 35%.

Any (i) foreign-sourced income which is not remitted to Malta and (ii) any foreign-sourced capital gains, whether or not remitted to Malta, are not usually subject to Maltese tax.

It may also be possible for beneficiaries to claim double tax relief under Malta’s wide network of Double Tax Treaties and Unilateral Double Tax Relief Mechanisms.

Eligibility Criteria

In order to be eligible to apply for special tax status under the United Nations Pensions Programme, applicants must satisfy the following conditions:

(i) Receipt of a UN Pension or Widow/Widower’s Benefit

The applicant must be in receipt of a United Nations pension or Widow/Widower’s benefit. Furthermore, at least 40% of the aforementioned pension must be received in Malta.

(ii) Qualifying Property Holding

The applicant must hold a Qualifying Property and occupy it as their primary residence. Qualifying Property holdings can take the form of a:

(a) Qualifying Owned Property:

– Immovable Property situated in Malta for at least €275,000; or

– Immovable Property situated in Gozo or the South of Malta for at least €220,000.

(b) Qualifying Rented Property:

– Immovable Property situated in Malta leased for not less than €9600 per annum; or

– Immovable Property situated in Gozo or the South of Malta for at least €8750 per annum.

Under the United Nations Pensions Programme Rules, the following localities are considered ot be in the South of Malta:

Birzebuggia, Cospicua, Fgura, Ghaxaq, Gudja, Kalkara, Kirkop, Luqa, Marsascala, Marsaxlokk, Mqabba, Paola, Qrendi, Safi, Santa Lucija, Senglea, Siggiewi, Tarxien, Vittoriosa, Xghajra, Zabbar, Zejtun and Zurrieq.

(iii) Other General Requirements

1. They must not be permanent or long-term residents of Malta;

2. They must be in receipt of stable and regular resources sufficient to maintain themselves without recourse to the social assistance system in Malta;

3. They must be in possession of sickness insurance;

4. They must be in possession of a valid travel document;

5. They must be able to communicate in English or Maltese;

6. They must be Fit and Proper persons.

The Application Procedure

Requirement of an Authorised Registered Mandatary (ARM)

All individuals seeking special tax status under the United Nations Pensions Programme shall authorise an Authorised Registered Mandatary to act on their behalf in respect of all applications, submissions and filings.

Application

The applicant must first complete and file an application to the Commissioner for Revenue (CFR) through the Authorised Registered Mandatary.

Upon submission of the application, the applicant must pay (i) an administrative fee of €4000 if the Qualifying Property is situated in Malta; or (ii) an administrative fee of €3500 if the Qualifying Property is situated in Gozo or the South of Malta.

Acknowledgement Letter

The CFR will then issue an Acknowledgement Letter and deliver it to the Authorised Registered Mandatary. The Acknowledgement Letter will state whether any additional documents need to be submitted and whether any of the submitted documents do not satisfy the requirements.

Due Diligence and Face-to-Face Meeting

The CFR will then conduct its Due Diligence procedure, including the holding of a face-to-face meeting.

Letter of Intent

If the Due Diligence procedure is successfully completed, the CFR will issue a Letter of Intent and deliver it to the Authorised Registered Mandatary.

Within twelve months from the date of issue of the Letter of Intent, the applicant, through the Authorised Registered Mandatary, must provide the CFR with following documents:

– A Certified Copy of the Final Deed of Sale (in the case of a Qualifying Owned Property) or Lease Agreement (in the case of a Qualifying Rented Property);

– A Completed Notice of Primary Residence.

The applicant will also need to pay the Minimum Tax and provide the CFR with a receipt confirming that the Minimum Tax has been paid.

Letter of Confirmation

Once the above have been submitted, a Letter of Confirmation will be issued confirming the applicant’s right to reside in Malta and Special Tax Status.