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Updated: June 2026

Case study · Malta · Tax

How a Couple Transitioned to Malta's FixedTax Status of €15,000 per Year

Tax relocation makes sense only when the figures are calculated in advance, not taken on faith. Following the reform, Malta's Global Residence Programme introduced a fixed minimum annual tax of €15,000 - beneficial for some, an overpayment for others. A couple of rentiers wanted to understand whether this regime suited them. We explain step-by-step how we calculated the tax model, structured income on a remittance basis, and established their Malta tax residency status.

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 a Couple Transitioned to Malta's Fixed Tax Status of €15,000 per Year
Contents

Case at a glance

Situation, solution and outcome in seven lines

Clients
Married couple living on capital income
Objective
Legal tax residency in the EU with predictable tax burden
Program
Malta, tax resident (Global Residence Programme), post-reform
Key Feature
Fixed minimum annual tax of €15,000
Mechanism
15% on remitted income (remittance basis), non-dom
Solution
Model calculation, income structuring, status establishment
Result
Status established, tax burden predictable

Client story

Client's Story

Where they started

The couple lived on capital income and sought not a "second country for show," but a clear tax home in Europe. Malta's GRP regime appeared logical: 15% on income remitted to the island, non-dom status, and predictable rules.

Why the standard route did not work

The reform added an important detail - a fixed minimum annual tax of €15,000. This means: no matter how much income you remit, the tax will not be less than this sum. For some, this is advantageous certainty; for others, it is unnecessary burden if minimal income is to be remitted.

What BRIDGES had to solve

The main mistake in such situations is to choose a regime based on marketing rather than actual figures. Everything depends on how much income the couple will realistically bring to Malta for living expenses and how much to keep outside it. Without calculation, it is easy to overpay or, conversely, violate the terms.

Why a standard answer would not do

They approached BRIDGES precisely for calculation and structure: to understand at what level of income remittance the fixed minimum becomes advantageous, and to organize cash flows so the regime worked in their favor.

We were offered Malta as "15 percent and that's it." But after the reform, there is a fixed minimum of €15,000 per year, and I wanted to understand whether this was beneficial for us specifically. Sergey sat down and calculated the model based on our income, showed what to bring to the island and what to keep outside. It became clear and predictable - we established the status with confidence.

Semeynaya · Client, living on capital incomeThe name and certain identifying details have been changed to protect confidentiality.

What Was at Risk

What Was at Risk

Tax regimes are selected based on actual figures, not slogans. The fixed minimum of €15,000 is certainty for some and overpayment for others. Without model calculation and income structuring, it is easy to either overpay or violate remittance basis conditions.

Overpaying if income remittance is modest yet the minimum remains €15,000;

  1. 01Choosing a regime based on advertising without calculating their actual tax burden;
  2. 02Violating remittance basis by mixing remitted and non-remitted income;
  3. 03Losing status due to non-compliance with residency requirements;
  4. 04Incorrectly establishing non-dom status and forfeiting preferential 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.

  1. 01
    Stage 1

    We analyzed the Global Residence Programme tax model after the reform: 15% on income remitted to Malta, with a fixed minimum of EUR 15,000 per annum—and demonstrated to the couple at what income remittance level the minimum is justified and at what level it is more advantageous to remit less.

  2. 02
    Stage 2

    We structured income sources into remitted and non-remitted categories under remittance basis rules: what to direct to Malta for living expenses, what to retain outside the island—to ensure the tax base is manageable and compliant with law.

  3. 03
    Stage 3

    We selected and registered qualifying residential property meeting GRP thresholds (rental accommodation) with contract registration—without this, status is not granted.

  4. 04
    Stage 4

    We registered the GRP status: application submission, confirmation of stable funds, medical insurance, non-domiciled status declaration, and commitment to the fixed minimum of EUR 15,000.

  5. 05
    Stage 5

    We arranged compliance with residency requirements—non-resident status in other jurisdictions, presence requirements—and prepared a payment schedule for the fixed annual tax.

Takeaway. The solution proved not to be "standard" but calculated: the analysis showed at what income remittance level the regime benefits them specifically, and the cash flow structure optimized the tax burden. The couple obtained a legal tax residence in the EU without surprises.

How We Solved the Issue

How We Solved the Issue

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

  1. 01

    Stage 1

    We analyzed the Global Residence Programme tax model after the reform: 15% on income remitted to Malta, with a fixed minimum of EUR 15,000 per annum—and demonstrated to the couple at what income remittance level the minimum is justified and at what level it is more advantageous to remit less.

  2. 02

    Stage 2

    We structured income sources into remitted and non-remitted categories under remittance basis rules: what to direct to Malta for living expenses, what to retain outside the island—to ensure the tax base is manageable and compliant with law.

  3. 03

    Stage 3

    We selected and registered qualifying residential property meeting GRP thresholds (rental accommodation) with contract registration—without this, status is not granted.

  4. 04

    Stage 4

    We registered the GRP status: application submission, confirmation of stable funds, medical insurance, non-domiciled status declaration, and commitment to the fixed minimum of EUR 15,000.

  5. 05

    Stage 5

    We arranged compliance with residency requirements—non-resident status in other jurisdictions, presence requirements—and prepared a payment schedule for the fixed annual tax.

  6. 06

    Stage 6

    We prepared and submitted the first annual tax return under GRP rules, confirming payment of the minimum and correct remittance basis application—status is secured.

Expert comment

Tax relocation without calculations is a lottery. After the reform, GRP introduced a fixed minimum of EUR 15,000 annually, and my first step is always to calculate: at what income remittance volume is this beneficial for a specific client. I showed this couple their own model—what to remit to the island, what to retain, where the benefit threshold lies. Only then did we register the status and configure remittance basis. My task is to ensure the client understands the long-term consequences, not to celebrate the slogan "15 percent."

Sergey Evdokimov, Managing Partner, BRIDGESSergey EvdokimovManaging Partner, BRIDGES

Outcome

What the client received

What Was Required
How We Accomplished It · Result
Determine if the regime is beneficial
tax model calculation · benefit threshold identified
Make the burden manageable
structuring under remittance basis · tax base under control
Register the status
residential property + non-dom status + application · GRP status obtained
Secure the regime
first annual tax return · minimum confirmed
Secure the regime
first annual tax return · minimum confirmed

The couple registered Malta's tax status under GRP with clear tax burden: the model was calculated for their income, cash flows were structured under remittance basis rules, qualifying residential property was registered, and the fixed minimum of EUR 15,000 was confirmed by the first tax return. The tax burden became predictable.

Practical takeaway

What matters in a similar situation

  • The solution proved not to be "standard" but calculated: the analysis showed at what income remittance level the regime benefits them specifically, and the cash flow structure optimized the tax burden. The couple obtained a legal tax residence in the EU without surprises.
  • This case demonstrates that tax regimes are selected based on figures. A fixed minimum is a tool that either works for you or against you; the difference is determined by model calculation and proper income structuring.

FAQ

Questions people ask in a similar situation

01What Did the Reform Change in GRP?

Among other changes, it fixed the minimum annual tax at EUR 15,000. Regardless of income remittance volume to Malta, the tax will not be less than this amount.

02How Is Tax Calculated Under GRP?

15% on income remitted to Malta, but not less than the fixed minimum of EUR 15,000 per annum. Income not remitted to the island is generally not subject to taxation.

03For Whom Is the Fixed Minimum Advantageous?

For those importing sufficient income to Malta, 15% must exceed or be close to the minimum threshold. With lower imports, the minimum may result in overpayment—therefore, a calculation is necessary.

04What is remittance basis?

The principle by which only income brought into the country is taxed, not worldwide income. Therefore, it is important to structure what to bring to Malta and what to hold offshore.

05Is it necessary to reside in Malta?

You must comply with the program's residency requirements, including qualifying accommodation and presence conditions, and not be a tax resident of another country. We will calculate specific details based on your situation.

06Considering a tax relocation but unsure about the figures?

We will calculate the GRP model for your income, show the break-even point of the fixed minimum, structure income flows under remittance basis, and secure your Malta tax status.

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.