Investment Migration – Malta
Malta for UK Nationals
The UK non-domicile regime was abolished on 6 April 2025. Malta’s remittance-based tax system, zero inheritance tax, and government-approved residency programmes offer UK nationals a compliant alternative base within the European Union. ARQ manages the full process in-house — residency, tax, estate planning, and relocation.
15%
GRP Flat Tax
On remitted income (GRP)
12,000+
British Nationals currently living in Malta
70+
Tax Treaties
Including UK-Malta DTA
0%
Inheritance Tax
Why UK Nationals are Moving & Reviewing their Tax & Estate Positions
A series of significant changes to the taxation of internationally mobile, high-net-worth individuals has accelerated interest in Malta residency planning. In the United Kingdom, the non-domicile regime was abolished from 6 April 2025. All UK-resident individuals are now taxed on worldwide income and gains on the arising basis, regardless of domicile. Separately, inheritance tax in the UK is now residence-based rather than domicile-based. Long-Term Residents — defined as individuals who have been UK tax-resident in 10 or more of the last 20 UK tax years — face UK inheritance tax on worldwide assets, with a trailing liability of three to ten years after departure. Offshore trusts that previously benefited from Excluded Property Trust status lost that protection on 6 April 2025.
For individuals affected by these changes, Malta’s non-dom remittance system offers a credible and compliant alternative base. The UK-Malta Double Taxation Agreement governs the interaction between the two jurisdictions, and ARQ provides the cross-border analysis needed to structure a departure and Malta residency in a way that minimises both UK trailing liabilities and Maltese compliance risk.
Malta’s Tax Advantages — The Remittance Basis for Non-Domiciled Residents
Malta taxes non-domiciled residents on a remittance basis. Foreign income and gains are not subject to Maltese tax unless they are remitted to Malta. Capital gains on assets situated outside Malta are fully exempt, even if remitted. Individuals holding residence under the GRP pay a flat rate of 15% on foreign income remitted to Malta, subject to a minimum annual tax of EUR15,000. Under TRP (available to EU/EEA/Swiss nationals, but not UK nationals post-Brexit), the same rates apply. For UK nationals, the GRP or MPRP are the relevant routes. ARQ manages both the permit and the annual tax compliance.
The UK IHT 10-Year Tail — And How Malta Residency Starts the Clock
UK Long-Term Residents who leave the UK do not immediately exit the UK IHT scope. The trailing period ranges from three years (for those UK tax-resident for 10–13 years) to 10 years (for those UK tax-resident for 20 years). Establishing Malta residency starts the countdown, but earlier residence qualifies more quickly. For every year a UK LTR delays their departure, the potential tail extends. ARQ analyses the IHT tail position as part of the pre-departure planning process and advises on the optimal sequencing of departure and Malta residency qualification.
EPT Note
For individuals who held Excluded Property Trust structures, the removal of EPT protection on 6 April 2025 does not mean restructuring is impossible or inadvisable. ARQ works with clients and their existing legal advisers to assess which assets are now within scope, what compliant restructuring options exist under the UK-Malta DTA framework, and how Malta’s trust legislation can be used in a post-EPT environment.
Malta Residency Programmes for UK Nationals
Following Brexit, UK nationals are classified as third-country nationals under EU law. This means they are eligible for the MPRP (indefinite residence, government contribution of €37,000) and the GRP (residence plus 15% flat tax, €15,000 minimum annual tax). UK nationals are not eligible for the TRP or MRP, which are reserved for EU/EEA/Swiss nationals. The MPRP now issues a temporary residence permit at the application stage, meaning UK nationals can relocate to Malta while the full application is processed over 6–8 months. ARQ manages both programmes and confirms eligibility at the initial consultation.
Malta Citizenship by Merit — A Pathway to EU Citizenship for UK Nationals
Malta’s Citizenship by Merit programme, introduced under Legal Notice LN159/2025, offers a selective naturalisation pathway to Maltese and EU citizenship for individuals whose exceptional achievements or contributions are of significant value to the Republic of Malta. For UK nationals, Maltese citizenship carries particular weight post-Brexit. It restores full EU citizenship rights, including the right to live, work, and travel freely across all 27 EU member states.
The programme is discretionary and merit-based. Applications are evaluated by an Independent Evaluation Board appointed by the Minister, guided by Malta’s long-term strategic framework under Vision 2050. Eligible fields include scientific research and innovation, entrepreneurship and economic development, technology and digital advancement, arts, culture and sport, philanthropy and humanitarian initiatives, and public health. The evaluation focuses on originality, measurable impact, and the relevance of the applicant’s contribution to Malta’s economy, global positioning, or societal development.
The process begins with a Proposal Letter submitted to the Community Malta Agency, setting out the applicant’s background and the outstanding contribution they intend to make. Following initial due diligence and Board review, approved applicants receive an in-principle letter of approval. Additional requirements include evidence of at least eight months of residence in Malta, access to adequate residential housing, a demonstrated command of English or Maltese, and evidence of genuine links to Malta consistent with the proposal.
ARQ is accredited by the Community Malta Agency and advises on Citizenship by Merit eligibility and the proposal submission process. Given the discretionary nature of the programme, early engagement with an accredited adviser is strongly recommended before submitting a proposal.
Relocating to Malta from the United Kingdom
Over 12,000 British nationals are already resident in Malta, and English is an official language; direct flights from London take approximately three hours, and Malta’s common-law legal framework (inherited from British governance) is familiar to UK nationals. ARQ’s relocation team provides end-to-end support, including residency permits, property search, banking, school registration, healthcare, and personalised orientation tours.
Considering Malta as Your Next Tax Residence?
ARQ’s Private Clients Team provides a confidential, obligation-free initial assessment covering your current UK position, programme eligibility, and the steps involved.
How ARQ Structures Your Transition to Malta
Step 1: UK Departure Analysis
ARQ reviews your current UK tax position, residency ties, and trailing liabilities — including IHT tail risk for Long-Term Residents and EPT exposure.
Step 2: Programme Selection
We identify the right Malta programme (GRP or MPRP) based on your nationality, income structure, and goals.
Step 3: Pre-Departure Tax Structuring
Where required, ARQ advises on asset structuring, trust arrangements, and the sequencing of your departure relative to your Malta application.
Step 4: Application and Tax Registration
We manage your Malta residency application, register you with the Maltese tax authorities, and establish your non-dom status from the outset.
Step 5: Ongoing Advisory
ARQ handles annual Maltese tax compliance, remittance tracking, residency renewals, and any ongoing cross-border structuring as your circumstances change.
FAQ's - Malta for UK Nationals
What is the remittance basis of taxation in Malta?
Under Malta’s remittance basis, non-domiciled residents pay Maltese income tax only on income and gains that are brought into or used in Malta. Foreign income and gains that remain outside Malta are not subject to Maltese tax. Capital gains arising outside Malta are exempt whether remitted or not. This is the same foundational principle as the former UK non-dom regime, and has been part of Malta’s tax code since the 1940s.
What replaced the UK non-dom regime in April 2025?
From 6 April 2025, the UK abolished the remittance basis for non-domiciled individuals. All UK residents are now taxed on worldwide income and gains on an arising basis. A four-year Foreign Income and Gains (FIG) exemption is available to new UK arrivals who have not been UK tax-resident in the preceding 10 years. Long-Term Residents, those UK tax-resident for 10 or more of the last 20 years, face UK inheritance tax on worldwide assets and a trailing IHT liability of 3 to 10 years after departure.
Does Malta have inheritance tax?
No. Malta does not impose inheritance tax, estate duty, wealth tax, or gift tax. For individuals with significant worldwide estates. Particularly those previously relying on Excluded Property Trust structures or UK non-dom IHT protections, Malta’s tax framework provides a compliant alternative with no equivalent charge on assets held outside Malta.
What happened to Excluded Property Trusts after April 2025?
From 6 April 2025, Excluded Property Trust protections for UK Long-Term Resident settlors were removed. Offshore trust assets that were previously sheltered from UK IHT now fall within scope. ARQ advises on compliant restructuring options using Malta’s non-dom framework, the UK-Malta Double Taxation Agreement, and, where appropriate, Malta’s trust and foundation legislation.
What is ARQ's accreditation?
ARQ Immigration Advisory Ltd is accredited by the Community Malta Agency and Residency Malta Agency for all Malta residence and citizenship programmes. Our licence number is AKM-ARQI-21.
What are the MPRP costs for UK nationals?
Government contribution €37,000, administrative fee €60,000, qualifying property purchase from €375,000 or property rental from €14,000 per year, plus a qualifying NGO donation of €2,000.
Can ARQ advise on UK tax exit alongside the Malta application?
Yes. ARQ covers both the immigration application (CMA-accredited, Licence AKM-ARQI-21) and the personal tax and estate planning advisory in-house. Your Malta residency, tax registration, and UK departure structuring are managed by a single team.
Submit your Malta Residency Consultation Request
Speak directly with ARQ’s Private Clients Team. Initial consultations are complimentary and without obligation.
Key Contact
David Borg
Partner – Tax & Advisory
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