We would like to inform you of recent legislative changes affecting Malta’s special tax status regimes. The Maltese Government has published the Individual Tax Programme Rules, 2026, which will replace the Global Residence Programme (GRP), The Residence Programme (TRP), the Malta Retirement Programme (MRP) and the UN Pensioners Programme for new applications submitted from 1st of January 2027.
The four existing programmes are not abolished in substance but consolidated into a single legislative instrument with harmonised administration, while preserving distinct eligibility criteria for each.
As a result, Malta’s Global Residence Programme (GRP) is changing significantly from 1 January 2027, when new applications will fall under the new Individual Tax Programme. Existing beneficiaries, as well as applications received by the Malta Tax and Customs Administration by 31 December 2026, will continue to be governed by the current GRP provisions until 31 December 2031, subject to ongoing compliance and the applicable cessation rules.
The new framework will bring a number of Malta’s existing special tax residence programmes under one umbrella. For third-country nationals who would currently apply under the GRP, the corresponding category will be known as Global Resident Status.
The principal tax benefits will remain: qualifying foreign-source income remitted to Malta will continue to be taxed at 15%. Foreign income not remitted to Malta and foreign capital gains, even if remitted, remain outside the scope of Maltese tax.
However, the minimum annual tax, property thresholds, application fee, dependant eligibility and duration of the status will all change.
What is the Global Residence Programme?
The “Global Residence Programme (GRP)” is a programme designed to attract individuals who are not nationals of the EU, EEA or Switzerland and who are not long-term residents. Individuals benefitting from this Programme are not precluded from working in Malta, provided they satisfy the requisite conditions for obtaining a work permit.
The GRP is particularly attractive to internationally mobile individuals and families who wish to establish a base in Malta while benefiting from Malta’s remittance-basis tax system.
Main benefits:
- Special tax status with the right to reside in Malta
- Unlimited days of residence in Malta each year, with visa-free travel to the 29 Schengen countries for up to 90 days in any 180-day period.
- Who can be included in the application: Spouse/civil partner, principally dependent children up to 25, direct relatives in the ascending line, and household staff, subject to conditions
- Relatively fast processing time: 4 to 6 months
Tax treatment:
- Qualifying foreign-source income remitted to Malta is taxed at 15%
- Foreign-source income that is not remitted to Malta generally remains outside the Maltese tax charge
- Foreign capital gains are generally not taxable in Malta, even where the proceeds are remitted, provided they are genuinely capital in nature
- Malta-source income is taxed separately under the applicable Maltese rules.
Principal changes for GRP applicants
Requirement | Current GRP | From 1 January 2027 |
Tax on qualifying foreign income remitted to Malta | 15% | 15% |
Minimum annual tax | €15,000 | €35,000 |
Minimum property purchase | €220,000–€275,000 | €700,000 |
Minimum annual rent | €8,750–€9,600 | €14,000 |
Application fee | €5,500 or €6,000 | €8,500 |
Duration of special tax status | Continues until 31 December 2031, subject to ongoing compliance and applicable cessation rules | Five years, renewable |
Renewal fee | None | €2,500 every five years |
The most significant tax change is the increase in the minimum annual tax from €15,000 to €35,000.
The 15% tax rate itself will remain unchanged, but applicants entering the programme from 2027 will face a substantially higher annual minimum commitment.
The minimum property-purchase threshold will also increase considerably to €700,000 (from min. €220,000), while the minimum annual rent will become €14,000 (up from min. €8,750).
The new framework will introduce a five-year fixed-term structure for special tax status, renewable for further five-year periods subject to continued eligibility and a €2,500 renewal fee.
The definition of a dependant will also become narrower. Parents, grandparents and dependent brothers or sisters will no longer qualify. Under the new rules, qualifying family members will include the beneficiary’s spouse or stable partner, minor children, children under 25 who are not economically independent, and adult children unable to maintain themselves because of serious illness or disability. The new Rules also recognise qualifying household staff, although they are not classified as dependants and remain subject to a number of conditions.
What happens to existing beneficiaries and 2026 applicants?
Existing GRP beneficiaries will not be required to transfer immediately to the new programme. Subject to continuing compliance, they may retain their current status during the transitional period ending on 31 December 2031.
The transitional provisions are also important for prospective applicants. The terms of the current framework will apply to applications received by the Malta Tax and Customs Administration by 31 December 2026 and will be applicable until 31 December 2031.
Applicants intending to rely on the current provisions should begin the process well before the deadline. A GRP application involves due diligence, tax planning, supporting documentation, property arrangements and coordination with the relevant Maltese professionals and authorities.
An important planning window
For some families already considering Malta, the difference between the current GRP and the new framework is material.
Applying under the present programme will mean retaining:
- the €15,000 minimum annual tax rather than €35,000
- the current lower property thresholds
- the current lower application fee
- more generous dependant eligibility
- the existing programme structure during the transitional
That does not mean that every family should rush to apply. Choosing a country of residence is an important long-term decision.
The right solution depends on the family’s objectives, lifestyle, income structure, property preferences, children’s education, future plans and other factors which are unique to each family.
However, for individuals and families for whom Malta and the GRP are already a suitable choice, the period before 31 December 2026 presents an important window to submit the application before the new requirements take effect.
Malta should not be selected solely for tax reasons. Nevertheless, its remittance-basis tax treatment, combined with the lifestyle offered by an English-speaking EU and Schengen country, can make the GRP a particularly attractive solution for the right family.
For more information, please get in touch with our Senior Advisor, Alexandra Kenna – akenna@valtd.com
