Highly Qualified Persons Programme
The Malta Highly Qualified Persons Rules builds on the success of Malta’s reputation in attracting highly professional individuals seeking an alternative residence base in a warm Mediterranean Island in the European Union.
The Programme seeks to entice highly professional individuals looking for an alternative residence base than their current domicile. Given the substantial expansion that the Maltese Islands have experienced in the finance, fintech, aviation, gaming and professional services spheres, this has created a strong demand for highly qualified workers to complement the local workforce. Individuals who avail from the Malta Highly Qualified Persons Programme benefit from a special tax status with a personal tax rate of 15% on employment income derived from a qualifying contract of employment in Malta up to a maximum of €5,000,000. Additional income generated through such employment (over the €5 million treshold) would not be subject to further tax.
Employment Legal Basis
Only employment contracts from companies that are licensed by the following entities are recognised under the scheme:
- The Malta Financial Services Authority
- The Malta Gaming Authority
- Companies holding an Air Operators Certificate or an Aerodrome Licence issued by Transport Malta.
An individual is eligible to apply for a special tax status under the Highly Qualified Persons Programme if he satisfies the following conditions:
- Income received by the professional amounts to at least €75,000 adjusted annually in line with the Retail Price Index. The minimum income (based on the Retail Price Index published by the Malta National Statistics Office) must exceed €84,991;
- He resides in accommodation that would be deemed normal in comparison to a comparable family in Malta;
- Employment with a company which falls under the definition of ‘eligible office’;
- The applicant must have necessary qualifications and at least 5 years of experience
- He must not be domiciled in Malta;
- The professional must not benefit under any other special tax programmes in Malta;
- He must be deemed to be a fit and proper person;
- The professional must be in possession of a health insurance policy covering himself and his dependents.
Senior positions which are eligible under this scheme include the following professions:
- Actuarial Professional
- Aviation Continuing Airworthiness Manager
- Aviation Flight Operations Manager
- Aviation Ground Operations Manager
- Aviation Training Manager
- Chief Executive Officer
- Chief Financial Officer
- Chief Commercial Officer
- Chief Insurance Technical Officer
- Chief Investment Officer
- Chief Operations Officer (including Aviation Accountable Manager)
- Chief Risk Officer (including Fraud and Investigations Officer)
- Chief Technology Officer
- Chief Underwriting Officer
- Head of Investor Relations
- Head of Marketing (including Head of Distribution Channels)
- Head of Research and Development; (including Search Engine Optimisation and Systems Architecture)
- Portfolio Manager
- Senior Analyst (including Structuring Professional)
- Senior Trader/Trader
- Odds Compiler Specialist
Individual income derived from employment in an ‘eligible office’ will not qualify for the scheme if a claim is made for any relief, deduction, reduction, credit or set-off of any kind except for any income tax deducted at source.
Taxation of Highly Qualified Persons
Individuals who register under this scheme benefit from a favourable tax rate of 15% on all income derived from their employment in Malta. This 15% flat rate is imposed up to a maximum of €5,000,000, and any excess of this amount is not subject to tax.
The tax benefits under this scheme apply to EEA and Swiss nationals for a maximum consecutive period of 5 years preceding the first year of assessment and to third country nationals for a maximum consecutive period of 4 years. EEA/Swiss nationals who avail themselves of this tax benefit shall be eligible upon application, for a one-time extension of 5 years, making the qualifying period, a maximum of 10 years of assessment.
This programme may be requested from The Office of the Commissioner for Revenue.