The government has consolidated various tax programmes for eligible qualified expatriates, replacing them with a single harmonised framework for taxation of their income.
What changed?
Until the end of 2025, there were various schemes running in parallel — the Highly Qualified Persons Rules, the Qualifying Employment in Innovation and Creativity (Personal Tax) Rules, and the Qualifying Employment in Aviation (Personal Tax) Rules — each with different criteria, eligible roles, and conditions.
These have now been replaced by a single set of rules: the Highly Skilled Individuals Rules, 2025 (Legal Notice 366 of 2025), which entered into force on 1 January 2026.
Key features
The new framework provides a flat tax rate of 15% on qualifying employment income, subject to a minimum annual tax liability of €10,000. The benefit is available for a period of up to 10 consecutive years.
Eligible individuals must hold a qualifying office or employment with a licensed or recognised entity in Malta, and must not have been resident in Malta for the three years immediately preceding their application.
Impact on existing beneficiaries
Persons already benefiting from one of the previous schemes may continue to do so under transitional provisions, or they may opt to migrate to the new framework if it is more favourable.
The harmonised rules aim to simplify administration, make Malta more competitive in attracting international talent, and provide greater clarity and certainty for employers and employees alike.
Further details are available on the Malta Legislation website.
