Malta changes tax statuses for foreigners from 2027: a EUR 35,000 minimum and property from EUR 700,000

In brief

• The document: Legal Notice 195 of 2026 under the Income Tax Act, Chapter 123. Published in the Government Gazette of Malta No. 21,686 of 14 July 2026, in force from 1 January 2027.
• ITP is not a residence permit and not a new programme. It is a tax status with a 15% rate on foreign income remitted to Malta. It brings four categories under one set of rules: global resident, EU, EEA, Swiss resident, retired pensioner and UN pensioner.
• The minimum tax for non-EU nationals and for EU nationals is EUR 35,000 a year instead of EUR 15,000. For pensioners it is EUR 15,000, for UN pensioners EUR 20,000.
• Property: a purchase from EUR 700,000 or a lease from EUR 14,000 a year, the same for the whole country. The lower thresholds for the south of Malta and Gozo are gone.
• Status is granted for 5 years and can be renewed. The application fee is EUR 8,500, the renewal fee EUR 2,500.
• Statuses granted by 31 December 2026, and applications received by that date, continue to apply until 31 December 2031.

What ITP is according to the notice

The notice was made by the Minister responsible for finance under articles 56(23) and 96 of the Income Tax Act. It is subsidiary legislation, not an act of parliament. It can therefore be changed as quickly as it was made, which is worth remembering in long-term planning.

In substance the document describes one mechanism. A foreigner applies to the Commissioner for Tax and Customs through an authorised representative. If the conditions are met, the Commissioner grants special tax status in writing. From then on, foreign income that the person, the spouse and the children remit to Malta is taxed at 15%. Income that is not remitted to Malta is not taxed under this rule. Other chargeable income is taxed separately at 35%.

It is important to understand what ITP is not. The notice says nothing about a residence permit, a visa or the right to work. These are tax rules. A residence permit for non-EU nationals is obtained separately under the immigration rules, as before. If what you need is permanent residence, that is a different programme, explained in the piece on Malta permanent residence MPRP.

One more point. The notice does not expressly repeal the old rules of the Global Residence Programme, The Residence Programme, the Malta Retirement Programme and the UN pensions programme. As at 16 October 2026 their consolidated texts on the Maltese legislation portal are unchanged. But the notice's own transitional rule sets a common end point: the old statuses continue until 31 December 2031. Maltese lawyers read the provision the same way.

What this means for you. ITP does not widen the options, it raises the entry price. If you were looking at Malta for the 15% rate, the decision has to be made before the end of 2026, otherwise you will be working with the new numbers.

Four statuses and who can apply

The notice splits applicants into four categories. A person can hold only one status, they cannot be combined. Nor can a person use another Maltese special tax regime at the same time, such as the one for highly qualified professionals.

Global resident is for nationals of countries outside the EU, EEA and Switzerland who do not hold long-term resident status in Malta. Nationals of Russia, Kazakhstan, Ukraine, Israel and the UAE fall here. EU, EEA, Swiss resident is for EU nationals who are not Maltese and do not hold the right of permanent residence. Both categories pay the same EUR 35,000 minimum.

Retired pensioner requires the pension to be at least 75% of chargeable income and to be received in Malta in full. The notice defines pension broadly: state pensions, regular payments from occupational and personal retirement plans, and annuities. Lump sums do not count as a pension. The old pensioner programme is covered in detail in the piece on the Malta Retirement Programme.

UN pensioner is a narrow category for recipients of a pension from the United Nations Joint Staff Pension Fund. The UN pension itself, when received in Malta, is exempt, and 15% is paid on other foreign income.

What got more expensive: minimum tax, property, fees

The rate has not changed, so at first glance nothing has happened. But for most families the actual payment is set not by the rate but by the minimum tax. It is due even if 15% of remitted income comes to less. The minimum is paid in full both in the year the status is granted and in the year it ends, and it is not refundable.

The EUR 35,000 threshold means simple arithmetic. At 15%, the minimum is covered by remitted income of EUR 233,333 a year. Anyone remitting less effectively pays a fixed amount. Previously the break-even point was EUR 100,000 of remitted income. A family remitting EUR 120,000 a year to live on paid EUR 18,000 in tax. Under the new rules it will pay EUR 35,000, almost 30% of the remitted income.

The change on property is even more visible. Under the old rules a flat in the south of Malta or on Gozo for EUR 220,000 was enough for the status. Now there is one threshold for the whole country: EUR 700,000 for a purchase. The rental threshold rises from EUR 9,600 to EUR 14,000 a year, and the lower threshold for the south and Gozo disappears too. For a renting family the five-year minimum budget of the status almost doubles.

The chart calculation: under the old rules, a EUR 6,000 fee, the EUR 15,000 minimum tax for five years and rent of EUR 9,600 a year come to EUR 129,000. Under the new rules, a EUR 8,500 fee, the EUR 35,000 minimum tax and rent of EUR 14,000 a year come to EUR 253,500. Living costs, insurance and the representative come on top in both cases. Property prices and purchase taxes are covered in the overviews of Malta real estate and Malta property taxes.

What this means for you. If your remitted income is below EUR 233,000 a year, you will pay not 15% but a fixed EUR 35,000. Work out your effective rate before you sign a lease.

Conditions to meet for all five years

The list of conditions in the notice is long, and most of them must be met not only on application but for as long as the status lasts. Breaching any one of them means losing the status from the start of the relevant year of assessment.

• The qualifying property must be the principal place of abode worldwide. Only the beneficiary, notified dependants and household staff may live there.
• The property may not be let or sublet: the notice names this expressly as a ground for losing the status.
• You may not spend more than 183 days in a calendar year in any other country.
• You need stable and sufficient resources for yourself and your family, a valid travel document and health insurance covering all risks across the EU.
• The beneficiary must not be domiciled in Malta and must not intend to establish domicile there within 5 years.
• You must be able to communicate in one of the official languages of Malta, that is Maltese or English, and pass a fit and proper check.
• The minimum tax is paid by 30 April together with a return confirming that the conditions are still met.

A separate rule deals with long-term and permanent residence. If the beneficiary or a family member obtains long-term resident status in Malta or the right of permanent residence, the ITP status ends and income is taxed under the general rules. The representative must check this every year as at 31 December and report to the Commissioner by 30 April, with a EUR 10,000 penalty for failing to do so. Changes in the family and loss of status must be reported within 4 weeks, otherwise there is a EUR 5,000 penalty.

There is also some relief. The Minister may pardon a failure to meet a condition if it was caused by unforeseen circumstances beyond the person's control, the person reported it and did their best to remedy it. How the 183-day rule works and what it is confused with, I explained in detail in the piece on the Global Residence Programme.

Transitional rules: what happens to those already in

The key provision for current participants is in rule 3. Statuses granted on or before 31 December 2026, and applications received by that date, continue to apply until 31 December 2031. This means that a person granted GRP status on an application filed in December 2026 will pay the EUR 15,000 minimum for another five years.

Note the wording. The text says "received", so the application must reach the Commissioner by the end of the year, not merely be sent. Applications go through an authorised registered mandatary, and the file has to be prepared in advance: the lease or purchase contract, insurance, proof of income and family documents. Starting in mid-December is risky.

The old statuses had no end date. Now everyone who obtained status under the old rules has one: 31 December 2031. The notice does not say expressly what happens after that. A move to ITP terms is the logical expectation, but that is my conclusion, not a rule. If you plan to live in Malta for more than five years, budget for the new EUR 35,000 minimum from 2032.

There is a separate proviso on property. Property bought for less than EUR 700,000 before the rules take effect may be treated as qualifying, but in the manner the Commissioner sets out in guidelines. As at 16 October 2026 I have not found such guidelines. Buying a EUR 300,000 flat now with a future ITP status in mind is therefore a decision without a guarantee.

What this means for you. If you are already in the programme, nothing changes for you until the end of 2031. If you are only considering it, the window for the old terms closes on 31 December 2026, and that is the date of receipt, not of sending.

Who ITP still suits and who it does not

The new regime remains attractive for families with large foreign income who remit more than EUR 233,000 a year to Malta. For them the minimum does not bite and they pay a straight 15%. More importantly, income not remitted to Malta is still not taxed. Capital outside Malta can work free of Maltese tax as long as you do not bring the income from it onto the island.

For middle incomes ITP becomes expensive. If a family remits EUR 80,000-150,000 a year, the ordinary non-dom regime in Malta may cost less. There, foreign income is also taxed only when remitted, but at progressive rates, and the EUR 5,000 minimum tax applies only if foreign income is at least EUR 35,000. The price difference can outweigh the convenience of a flat rate. The mechanics are in the analysis of the non-dom regime in Malta, and the full tax picture is in the piece on taxes in Malta.

Pensioners should recalculate especially carefully. The minimum for a couple rose from EUR 8,000 to EUR 15,000, which is 15% of a pension of EUR 100,000 a year. With an ordinary pension it is better to look at other EU countries where a foreigner's pension is taxed at a reduced rate. Pension regimes are compared in the pieces on the 7% tax for pensioners in Greece and retiring to Cyprus.

For very large fortunes Malta competes with lump-sum tax regimes. In Greece that is EUR 100,000 a year for all worldwide income, details in the analysis of the Greek non-dom regime. The Maltese option is cheaper at the minimum but taxes all remitted income at 15% with no upper cap.

Mistakes I see when people choose Malta

1. Calculating at 15% instead of at the minimum. With remitted income of EUR 100,000, from 2027 you pay EUR 35,000, not EUR 15,000.
2. Buying a cheap flat for a future status. The EUR 700,000 threshold applies nationwide, and the exception for cheaper purchases depends on Commissioner guidelines that do not exist yet.
3. Letting the qualifying property while living elsewhere. Letting and subletting are expressly named as grounds for losing the status.
4. Confusing a tax status with a residence permit. ITP gives no right to live in Malta; that is a separate matter with the immigration authority.
5. Sending the application in the last days of the year. The rule refers to an application received by 31 December 2026, and delays on the side of the representative or the documents are your risk.
6. Forgetting the 183 days. The status is lost if you spend more than half the year in any other country, even without becoming tax resident there.

What everyday life and a budget on the island look like is shown in the overview of the cost of living in Malta. For Russian nationals, specific questions about banks and source-of-funds checks are covered in the piece on Maltese residence for Russians.

What to do before 31 December 2026

If Malta is in your plans, you have about ten weeks. I would go in this order.

1. Estimate your remitted income for the next five years and compare three options: GRP under the old rules, ITP from 2027 and ordinary non-dom.
2. If the old terms are better, choose property at the old thresholds: a lease from EUR 9,600 a year or a purchase from EUR 275,000, lower in the south of Malta and on Gozo.
3. Gather documents for the whole family: passports, EU-wide health insurance, proof of stable income and of its source.
4. Choose an authorised registered mandatary. Without one the application will not be accepted, and all correspondence with the tax authority goes through them.
5. File the application so that the Commissioner receives it by 31 December 2026, and keep proof of receipt.

A detailed review of the old programme and scenarios is in the Malta Global Residence Programme guide. If you are comparing Malta with Portugal, see the piece on choosing between Portugal and Malta.

My conclusion

ITP is not a reform that opens new options, it is a higher price for the same 15% rate. The minimum tax has gone up 2.3 times, the property threshold 2.5 to 3 times, and the status now has a term. Malta is deliberately keeping the regime for people with genuinely large incomes and cutting off those who used it as an inexpensive tax address in the EU.

Current participants have five quiet years until the end of 2031. For those choosing now, 2026 is the last chance to get in on the old numbers. My advice is not to decide on the rate but to calculate on the minimum and on the cost of property for the whole term.

How this piece was prepared

The piece is based on the text of Legal Notice 195 of 2026 (Individual Tax Programme Rules, 2026) from the Maltese legislation portal, published in Government Gazette No. 21,686 of 14 July 2026, and on the consolidated texts of the current rules of the Global Residence Programme, The Residence Programme, the Malta Retirement Programme and the UN pensions programme from the same portal. All figures were checked against the texts on 16 October 2026. Commissioner for Tax and Customs guidelines on the new rules had not been found as at that date; the piece will be updated when they appear. This is not tax advice on any specific situation.