Zhang from Hong Kong holds crypto assets and earns regular staking income. The money accrues in his wallet, tied to neither a salary nor a country, and he did not know which rules applied to taxing it.
Zhang did not want to live in a grey zone. He needed a clear, lawful regime where he could see in advance how much he would pay and when, and that would raise no questions with banks or tax authorities.
We obtained Malta's GRP status for him. Under its rules foreign income is taxed at 15% only on the part remitted to Malta, plus an annual minimum tax applies. Below we explain how we fitted the staking income into this regime.
Case at a glance
Situation, solution and outcome in seven lines
Client
Zhang, about 35, a crypto holder, from Hong Kong
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.
Staking income kept coming in, and I did not understand where to pay tax on it. Tomas placed it into Malta’s tax regime and keeps records of every payout. Now everything is legal and predictable.
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;
01That GRP operates on a remittance basis: foreign income is taxed only if remitted to Malta;
02That foreign income remitted to Malta is taxed at a rate of 15%;
03That a statutory annual minimum tax applies;
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%
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.
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.
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.
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.
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. 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.
01
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.
02
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.
03
We qualified the income as foreign
We correctly classified staking income as foreign so that the remittance basis applies properly to it.
04
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.
05
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.
06
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.
How the work went
From first contact to the result
01We anchored the requirement for legality
02We selected GRP on a remittance basis
03We qualified the income as foreign
04We structured cash flows under the regime
05We accounted for the 15% rate and annual minimum
06We secured the lawful regime
The sequence and timing reflect this specific case and depend on how complete the documents are and on the decisions of the competent authorities.
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.
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%.
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.
The remittance basis and the 15% rate in Malta let staking income fit a clear legal regime. We will look at your case.
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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.
06Which documents were key in this case?
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. 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.
07Why did the standard route not suit the client?
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.
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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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.
