Malta taxes non-domiciled residents on a remittance basis. Foreign income and gains are not subject to Maltese tax unless they are remitted that is, brought into or used in Malta. Income and gains arising in Malta are taxed at standard progressive rates. Capital gains on assets situated outside Malta are fully exempt, even if remitted. This framework has been in place since Malta’s Income Tax Act, introduced under British governance in the 1940s, and remains one of the most competitive personal tax regimes in the European Union.

Malta’s Personal Tax Framework for Non-Domiciled Residents

Malta’s income tax legislation distinguishes between individuals who are resident and domiciled in Malta and those who are resident but not domiciled. For non-domiciled tax residents, known as Res Non-Doms, the following applies:

• Income and capital gains arising in Malta are fully taxable at progressive Maltese rates.
• Foreign income remitted to Malta is taxable at applicable programme rates (15% flat for GRP and TRP beneficiaries, subject to minimum annual tax).
• Foreign income not remitted to Malta is not subject to Maltese income tax.
• Capital gains arising outside Malta are not subject to Maltese tax, even if remitted.

This framework has been in place since Malta’s Income Tax Act was introduced under British governance in the 1940s. Its British legal origins mean the structure is familiar to UK-qualified advisers and internationally mobile clients from common law jurisdictions.

Tax Rates Under the Global Residence Programme (GRP) and The Residence Programme (TRP)

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. Income arising in Malta is taxed at 35%. Under TRP (available to EU, EEA and Swiss nationals), the same 15% flat rate applies, also subject to a EUR15,000 minimum. Capital gains arising outside Malta are exempt in both cases. These rates are fixed by statute and do not change with the level of remitted income, making forward tax planning straightforward.

Why Internationally Mobile Individuals Are Reviewing Their Tax Position

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.