Malta tax residence for non-EU nationals

Dr. Jean-Philippe Chetcuti | 27 May 2013

Chetcuti Cauchi Advocates CCMalta default banner

The 2011 High Net Worth Individual Residence Rules for Liechtenstein, Iceland and Norwegian nationals regulate the issue of Malta residence permits to Liechtenstein, Iceland and Norwegian nationals. Liechtenstein, Iceland and Norwegian nationals Hight Net Worth Individuals eligible under this scheme will be subject to Malta tax at a flat rate of 15% on a remittance basis, that is, only on foreign source income if remitted to Malta.

For new applicants, this scheme replaces the former Malta Residents Scheme Regulations.  Malta's new Liechtenstein, Iceland and Norwegian nationals HNWI Tax Residence Scheme:

Liechtenstein, Iceland and Norwegian High Net Worth Individuals rules:

The following is a summary of the applicable requirements to Liechtenstein, Iceland and Norwegian High Net Worth Individuals or families under the Malta HNW Residence Scheme:

1. Financial Background Stable & regular income
2. Property Purchase; or Minimum of EUR 400,000
    Property Rental Minimum of EUR 20,000
    Property Subletting / Sharing Not allowed
3. Tax Rate 15% Foreign source income remitted income to Malta
35% Malta source income
4. Annual Minimum Tax Payment Main Applicant : EUR 20,000 Dependant : EUR 2,500
5. Health Insurance Required
6. Max Residence in any other country < 183 days
7. Malta domicile allowed No
8. Local Business / Employment Allowed


Taxation of Non-EU HNWI Residents

Residence permit holders under the HNWI Residence Scheme are precluded from shifting their domicile to Malta.  As non-domiciled residents of Malta, residence permit holders are taxable on a remittance basis.  Resident non-doms are not subject to tax on foreign sourced income that is not remitted to Malta and on foreign capital gains, whether remitted or not.

Foreign capital gains are subject to tax at a flat rate of 15% subject to a minimum of EUR 20,000 for the main permit holder and a further EUR 2,500 for each additional dependent included in the residence permit.

Existing Malta Permanent Residents

Malta Permanent Residence Permit holders under the former Permanent Residence Scheme will continue enjoying their former status. However, those who sell the property to which their permit refers or terminates their existing lease must acquire a Qualifying Property Holding or lease according to the thresholds of the new HNWI Residence Scheme.


Request More Information

Please send me legal and other updates
Reference Materials