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Tax Treatment of Highly Skilled Individuals Rules

  • Sergio Montebello
  • 3 days ago
  • 2 min read

On the 23rd January 2026, the long-awaited legal notice 20 of 2026 introducing the Tax Treatment of Highly Skilled Individuals Rules was published. The new programme replaces existing incentive regimes mainly the Highly Qualified Persons Rules, but keeps the main features of the previous programmes, namely the 15% flat tax rate on qualifying employment income. 


Eligibility Conditions

  • The employee must earn taxable employment income in Malta under a qualifying contract of employment, amounting to at least €65,000 per year,  which must increase by €10,000 every 5 years.

  • The employee must be employed under Maltese law and  have adequate and specific competence acceptable to the competent authority.

  • They must hold relevant professional qualifications and perform duties in an eligible office.

  • The employee cannot have ever benefited under article 6 of the Income Tax Act.

  • They must demonstrate that they:

    - has stable and sufficient financial resources to support himself and his/her family in Malta without relying on social assistance;

    - lives in suitable accommodation meeting normal standards and health and safety requirements in Malta;

    - holds a valid travel document;

    - has private medical insurance covering risks normally insured for Maltese nationals, including also covering the family;

    - is not domiciled in Malta.

 

Special Tax Status and application process


The flat tax rate of 15% applies to income derived from a qualifying contract of employment, with no entitlement to reliefs, deductions, credits, or set-offs of any kind.  The 15% rate applies to emoluments up to €7 million per annum, after which a 35% tax rate applies. Applications for the programme are to be submitted to the Competent Authority up to 31 December 2035. The special tax status applies for a period of five years, which may be extended twice, up to a maximum eligibility period of 15 years.


Eligible Offices


The eligible offices are mainly C level and top positions within employers licensed by a Maltese competent authority (MFSA, Malta Gaming Authority, Transport Malta, Malta Enterprise, Office of the Chief Medical Officer) and are employed in sectors involving financial services, gaming, aviation, maritime, offshore oil & gas, family offices, health (ART), and STEM.


Should you be interested, we would be more than happy to assist your clients with exploring possible applications under the new programme.





Get in Touch:



Josef Mercieca

jmercieca@quazar.mt / +356 2388 4600



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