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Updated: June 2026

Case study · Malta · Residence permit

How crypto-staking income was classifiedunder Malta's tax regime (GRP)

Crypto-staking income is regular but "stateless": it accumulates in a wallet, and it is unclear where and how to tax it. Our client wanted a clear, lawful regime, not a gray zone. Malta's GRP tax status was ideal because it is based on convenient logic for such income—the remittance basis. We explain how we classified staking income under this regime.

Sergey EvdokimovSergey EvdokimovManaging Partner, BRIDGESReading time9 min readVerificationReviewed by an expert

This case is based on a real matter. The name and certain identifying details have been changed to protect confidentiality.

BRIDGES client story - How crypto-staking income was classified under Malta's tax regime (GRP)
Contents

Case at a glance

Situation, solution and outcome in seven lines

Client
Holder of crypto-assets with staking income
Objective
Clear and lawful tax regime for crypto-income
Program
Malta, Global Residence Programme (GRP)
Regime logic
Remittance basis: foreign income is taxed only if remitted to Malta
Rate
15% on foreign income remitted to the country
Minimum
Statutory annual minimum tax
Result
Staking income classified under the regime lawfully and predictably

Client story

Client's story

Where they started

The client received regular income from crypto-staking and faced a typical problem with such income: it is "nowhere." Funds are credited to a crypto wallet, not tied to a specific salary or country, and the individual does not understand which rules apply to tax them. He did not want to live in a gray zone—he needed a clear, lawful regime that would not raise questions.

Why the standard route did not work

Malta's GRP status suited this request due to its logic—the remittance basis. The essence is as follows: foreign (overseas) income is not fully taxed in Malta, but only in the portion that is actually remitted to Malta. What remains outside the country and is not deposited into Maltese accounts is not subject to Maltese tax. Foreign income remitted to Malta is taxed at a rate of 15%. At the same time, a statutory annual minimum tax applies—it is paid regardless of the remittance amount.

What BRIDGES had to solve

For staking income, this is convenient: the client controls how much and when to remit to Malta and understands the tax consequences in advance. It was important to correctly classify the income as foreign, structure the flows so the regime applied properly, and account for the annual minimum—so everything would be both lawful and predictable.

Why a standard answer would not do

At BRIDGES, we obtained GRP status for the client and structured the tax logic for his crypto-income: applied the remittance basis, fixed the 15% rate on remitted funds, and accounted for the annual minimum tax. Staking income ceased to be "stateless"—it fit into a clear and lawful regime.

My staking income was flowing in constantly, but I really didn't understand where to pay taxes on it—it seemed to belong to no one. I didn't want to venture into a gray zone. BRIDGES proposed Malta's GRP status: foreign income is taxed only if you remit it to Malta, and at 15% at that, plus there's an annual minimum. This worked perfectly for me: I decide how much to bring into the country and know the tax in advance. They obtained the status and structured all the logic for my crypto-income. Now everything is lawful and predictable, and I'm not in a gray zone.

Dmitry · Holder of crypto-assetsThe name and certain identifying details have been changed to protect confidentiality.

What was at risk

What was at risk

There was no disaster—there was uncertainty and risk of a gray zone. "Stateless" staking income can easily remain without a clear regime, leading to tax risks and questions when moving funds. The danger was not structuring the income and taxing it chaotically or not at all. The key was to fit it into a clear regime—the GRP remittance basis—and apply the rules correctly.

That staking income is "stateless" and easily drifts into a gray zone without a regime;

  1. 01That GRP operates on a remittance basis: foreign income is taxed only if remitted to Malta;
  2. 02That foreign income remitted to Malta is taxed at a rate of 15%;
  3. 03That a statutory annual minimum tax applies;
  4. 04That the income must be correctly classified and flows structured under the regime.

The logic of the solution

How the matter progressed: from checks to result

The chart is built from the facts of this matter and shows the logic of the work without decorative or unverified data.

Outcome15%
  1. 01
    Stage 1

    We anchored the requirement for legality. First we understood the key point: the client needed not a "way to avoid paying," but a clear lawful regime for crypto income without gray areas.

  2. 02
    Stage 2

    We selected GRP on a remittance basis. We proposed Maltese GRP status precisely because of its logic: foreign income is taxed only upon transfer to Malta - convenient for "stateless" staking income.

  3. 03
    Stage 3

    We qualified the income as foreign. We correctly classified staking income as foreign so that the remittance basis applies properly to it.

  4. 04
    Stage 4

    We structured cash flows under the regime. We helped organize fund movements so that tax arises under regime rules - on amounts transferred to the country - and the client independently manages transfer volume.

  5. 05
    Stage 5

    We accounted for the 15% rate and annual minimum. We fixed taxation of transferred income at 15% and the established annual minimum tax - to ensure the full picture is clear and predictable.

Takeaway. Conclusion: GRP operates on a remittance basis - foreign income (including staking income) is taxed in Malta only upon transfer to the country, at 15%, subject to an established annual minimum. The holder independently manages transfers.

How we solved the task

How we solved the task

The work was split into verifiable stages so that every conclusion rested on documents.

  1. 01

    Stage 1

    We anchored the requirement for legality. First we understood the key point: the client needed not a "way to avoid paying," but a clear lawful regime for crypto income without gray areas.

  2. 02

    Stage 2

    We selected GRP on a remittance basis. We proposed Maltese GRP status precisely because of its logic: foreign income is taxed only upon transfer to Malta - convenient for "stateless" staking income.

  3. 03

    Stage 3

    We qualified the income as foreign. We correctly classified staking income as foreign so that the remittance basis applies properly to it.

  4. 04

    Stage 4

    We structured cash flows under the regime. We helped organize fund movements so that tax arises under regime rules - on amounts transferred to the country - and the client independently manages transfer volume.

  5. 05

    Stage 5

    We accounted for the 15% rate and annual minimum. We fixed taxation of transferred income at 15% and the established annual minimum tax - to ensure the full picture is clear and predictable.

  6. 06

    Stage 6

    We secured the lawful regime. Staking income ceased to be "stateless": it fell under the clear GRP regime - lawfully, predictably and under the client's own control.

Expert comment

Staking income is classic "stateless" income: it flows into a wallet, is not tied to any country, and the person genuinely does not understand where to report it for tax purposes. Venturing into gray areas is risky, and no clear regime exists. Maltese GRP works well here because of its logic - the remittance basis. Foreign income is not taxed in full in Malta, only the portion you actually transfer to the country, and at 15%. What remains outside Malta is not subject to Maltese tax. There is also an established annual minimum tax, which is paid in any case. For crypto income this is convenient: the client decides independently how much to transfer to Malta and knows the tax in advance. Our work is to correctly qualify the income as foreign and structure the cash flows under the regime. We did this - and staking income became lawful and predictable, without gray schemes.

Sergey Evdokimov, Managing Partner, BRIDGESSergey EvdokimovManaging Partner, BRIDGES

Outcome

What the client received

What was required
How we did it · Result
Exit gray areas
GRP status · lawful regime
Clear logic
remittance basis · tax on amounts transferred to the country
Predictable rate
15% on transferred income + annual minimum · picture is clear in advance
Control
client manages transfers · independently determines tax base
Control
client manages transfers · independently determines tax base

The situation: the client received "stateless" income from cryptocurrency staking and wanted a clear lawful regime instead of gray areas. What we did: we anchored the requirement for legality; selected GRP on a remittance basis; qualified income as foreign; structured cash flows under the regime; accounted for the 15% rate and annual minimum. What the client received: staking income under a clear GRP regime - taxed only on amounts transferred to Malta, at 15%.

Practical takeaway

What matters in a similar situation

  • Conclusion: GRP operates on a remittance basis - foreign income (including staking income) is taxed in Malta only upon transfer to the country, at 15%, subject to an established annual minimum. The holder independently manages transfers.
  • The client's crypto income became lawful and predictable - because we fit it into the GRP regime on a remittance basis rather than leaving it in a gray area.

FAQ

Questions people ask in a similar situation

01How is cryptocurrency staking income taxed in Malta under GRP?

On a remittance basis: foreign income is subject to Maltese tax only on the portion transferred (remitted) to Malta, at a rate of 15%. Income remaining outside the country is not subject to Maltese tax. An annual minimum tax applies.

02What is remittance basis?

It is a principle whereby foreign income is not taxed in full, but only on the portion actually transferred to the country. Income remaining abroad and not transferred to Malta is not subject to Maltese tax.

03Is there a minimum tax?

Yes, GRP status provides for an established annual minimum tax, which is paid regardless of the volume of transferred income. Clarify the exact amount with the competent authorities.

04Is this a lawful scheme?

Yes, GRP is an official Maltese tax status, and the remittance basis is its standard logic. It is important to correctly qualify income as foreign and properly apply the regime rules; this is not a gray scheme but an established regime.

05Do I manage the tax base independently?

To a significant extent, yes: since taxation applies only to funds transferred to Malta, the holder independently decides how much and when to bring into the country, and understands the tax implications in advance. Specific details should be worked through with a tax consultant.

06Earning income from crypto-staking and seeking clear tax treatment?

We will arrange your Maltese GRP status and structure the tax logic based on your crypto-income under remittance basis: tax only on funds transferred to the country at a rate of 15%, with an annual minimum threshold - making staking income lawful and predictable, with no grey areas.

About the author

Sergey Evdokimov

Author: Sergey Evdokimov

Managing Partner, BRIDGES

As Founder and Managing Partner of BRIDGES, I am responsible for the firm's strategy and personally lead its most complex client matters, including cases in which citizenship or residence decisions require a strategic view and consideration of capital.

I begin by defining the objective: the outcome the client needs, the facts that affect the choice, and the matters that require further review. I then establish the available directions, the sequence of work, and the key decision points.

Once the strategy has been agreed, I oversee the BRIDGES team's key decisions and remain involved at the stages that shape the course of the matter. The purpose is to give the client a clear rationale for the chosen direction and a precise understanding of the next steps.

Prepared on the basis of BRIDGES practice and reviewed by a subject-matter expert.

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Dmitry NagyInternational Tax Consultant, BRIDGES
Dmitry Nagy, International Tax Consultant, BRIDGES

Names and certain details have been changed to protect client confidentiality. The result described reflects one specific situation and is neither a public offer nor a guarantee of a similar outcome. Programme terms are stated as of 2026 and may change - please confirm current parameters with a BRIDGES consultant.