The Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules

Eligibility Conditions

To benefit from the reduced tax rate, the individual must:

• Not be domiciled in Malta
• Be employed in an eligible office and earn minimum annual emoluments of €65,000
• Have his first employment in Malta under a qualifying contract, with no prior income taxable under Article 4(1)(a) or (b) of the Income Tax Act before 1 January 2025
• Be protected under Maltese employment law, possess adequate competence, and hold professional qualifications
• Not have previously benefited under Article 6 of the Income Tax Act (Investment Services and Insurance Expatriate Scheme)
• Fully disclose and declare all income related to the qualifying employment
• Reside in adequate accommodation, have stable financial resources, hold a valid travel document, and maintain private medical insurance for themselves and their family
• Demonstrate that they perform duties related to an eligible office

Special Tax Status & Income Thresholds

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. To qualify, the individual must earn minimum annual emoluments of €65,000, which will be adjusted by €10,000 every five years. The 15% rate applies to emoluments up to €7 million per annum.

Application Process & Timeframes

Applications must be submitted to the Malta Financial Services Authority (MFSA) between 1 January 2025 and 31 December 2034, with no further applications accepted after 31 December 2035. Once approved, the special tax status applies for a period of five years, which may be extended twice, each time for an additional five years. The scheme will not apply to income earned after 31 December 2040.

Eligible Offices Include

• Head of the Back Office and, or Chief Executive Officer, General Manager, Country Head, Managing Director or equivalent designation

• Chief and, or Head Risk Officer

• Chief and, or Head Compliance and Anti-Money Laundering Officer

• Chief and, or Head Risk Officer, including Fraud and Investigations Officer

• Portfolio Manager

• Chief and, or Head Investment Officer

• Senior Trader

• Senior Structuring Professional

Eligible Entities Include

• Single Family Offices:
  • Fund managers exempt under Investment Services Act regulations 3(1)(f) or 3(1)(t)
  • Registered trustees investing in Notified PIFs
  • Licence holders investing private wealth without raising external capital
• Multi Family Offices:
  • Licence holders investing private wealth without raising external capital
• Back Office & Treasury Management Providers:
  • Confirmed in writing by the competent authority as servicing the above entities