The Tax Treatment of Highly Skilled Individuals Rules

Conditions for Eligibility:

• The individual must earn taxable employment income in Malta under a qualifying contract of employment, amounting to at least €65,000 per year;

The €65,000 minimum threshold will be increased by €10,000 every five years.

• Must be recognised as an employee under Maltese law, perform genuine and effective work for or under the direction of another person, be remunerated, and possess adequate and specific competence acceptable to the competent authority.
• Must hold relevant professional qualifications and perform duties in an eligible office.
• Must not have previously benefited under article 6 of the Income Tax Act.
• Must fully disclose and declare for Maltese tax purposes all employment income under the qualifying contract.
• One must demonstrate that s/he:
  • 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, for him/herself and his/her family;
• is not domiciled in Malta.

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.  The 15% rate applies to emoluments up to €7 million per annum.

Application Process & Timeframes

Applications must be submitted to the Competent Authority between 1 January 2026 and 31 December 2035, with no further applications accepted after 31 December 2036. 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.

Eligible Offices

Eligible offices span across various sectors such as financial services, gaming, aviation, maritime, offshore oil & gas, family offices, health (ART), and STEM, as listed in detailed Schedules attached to the legal notice.

Applications are assessed by the relevant competent authority (e.g. MFSA, Malta Gaming Authority, Transport Malta, Malta Enterprise, Office of the Chief Medical Officer).

Transitional Provisions

The Tax Treatment of Highly Skilled Individuals Rules include transitional provisions for individuals who, as at 31 December 2025, were beneficiaries under the following existing regimes:

• the Highly Qualified Persons Rules;
• the Qualifying Employment in Innovation and Creativity (Personal Tax) Rules;
• the Qualifying Employment in Aviation (Personal Tax) Rules;
• the Qualifying Employment in Maritime Activities and the Servicing of Offshore Oil and Gas Industry Activities (Personal Tax) Rules; and
• the Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules.

Such individuals may be considered beneficiaries under the new regime provided that an application is submitted to the relevant competent authority. The transition is not automatic and is subject to the satisfaction of the applicable conditions.

The application for transition must be submitted no later than 31 December 2028.

Forvis Mazars' view:

The Tax Treatment of Highly Skilled Individuals Rules, 2026 represent a positive and welcome development in Malta’s personal tax framework. The introduction of a single, consolidated regime replacing multiple legacy schemes enhances clarity, consistency, and administrative efficiency for both taxpayers and the authorities.

By streamlining the previous preferential regimes into one unified framework, the new rules provide greater certainty and transparency, while maintaining Malta’s competitiveness in attracting senior talent. This framework reinforcing Malta’s position as an attractive hub for highly skilled professionals.

Forvis Mazars considers this regime to be an effective incentive for internationally mobile professionals and employers seeking a stable, well‑regulated jurisdiction with a clear tax offering. The transitional provisions further support continuity by allowing existing beneficiaries to migrate into the new framework.

We encourage current and potential beneficiaries to review their individual circumstances in light of the new rules, including eligibility, timelines, and long‑term planning considerations. Forvis Mazars would be pleased to assist with eligibility assessments, transition applications, and ongoing compliance, and to provide tailored advice on how the regime may be leveraged effectively.