Malta's Individual Tax Programme 2027: GRP, TRP and the Retirement Programme Merge, and the €15,000 Minimum Tax Becomes €35,000

For more than a decade, Malta ran four separate flat-tax programmes for foreigners: the Global Residence Programme for non-EU nationals, the Residence Programme for EU, EEA and Swiss nationals, the Malta Retirement Programme for pensioners and a niche programme for United Nations pensioners. Each had its own rules, its own fees and its own minimum tax. On 14 July 2026 the government published their successor.

Legal Notice 195 of 2026, the Individual Tax Programme Rules, 2026, appeared in Government Gazette No. 21,686 and comes into force on 1 January 2027. It puts all four regimes into one set of rules with four categories of "special tax status". The 15% rate survives. Almost everything around it gets more expensive, and the biggest single change is the minimum tax for the two categories most foreigners use: it rises from €15,000 to €35,000 a year.

If you hold GRP or TRP status today, or were planning an application, the dates in the rules matter more than the headline number. The window to apply under the current terms closes on 31 December 2026.

One Programme, Four Categories

Rule 3(1) of the new rules lists the four categories of special tax status:

• Global resident status, for third-country nationals who are not long-term residents of Malta. This is the successor to the Global Residence Programme.
• EU, EEA, Swiss resident status, for EU, EEA and Swiss nationals who are not Maltese and not permanent residents of Malta. This replaces the Residence Programme, usually called the TRP.
• Retired pensioner status, the successor to the Malta Retirement Programme.
• UN pensioner status, the successor to the United Nations Pensions Programme.

All four categories share the same application route, the same fee, the same property thresholds and the same list of conditions. What differs is who can apply and how much minimum tax they pay. No one can hold two categories at the same time.

Legally, all of these regimes sit on the same foundation: article 56(23) of the Income Tax Act, which lets the Minister grant a "special tax status" at 15% and requires a minimum tax. L.N. 195 does not revoke the four older sets of rules. It does something more practical. Its rule 3(3) says that any special tax status granted up to 31 December 2026, including any application received by that date, "shall continue to apply until 31st December 2031". In other words, the old regimes get a fixed end date, and the new programme takes over from 2027.

What Changes: Old Terms Against New Terms

The table below sets the old GRP and TRP terms, taken from S.L. 123.148 and S.L. 123.160, against the new global and EU/EEA/Swiss categories.

Three changes stand out.

The minimum tax more than doubles. Under rule 5(1), holders of global resident or EU/EEA/Swiss status pay at least €35,000 in every year of assessment. Like the old rules, the minimum is payable in full in the year the status is granted and in the year it ends. A part year costs the same as a full year.

The regional discount disappears. The old rules gave cheaper thresholds for Gozo and a defined list of southern localities. The new definitions of "qualifying owned property" and "qualifying rented property" have one number each, wherever the property is. A property bought before the rules come into force for less than €700,000 can still count, but only as the Commissioner determines in guidelines under article 96(2) of the Income Tax Act. The rules leave that detail entirely to the guidelines, so an older, cheaper home is not a safe assumption until they are in your hands.

Status now has a fixed term. The old rules set no term at all. Special tax status now runs for five years. Renewal is at your option, costs €2,500 and "shall not be unreasonably withheld", but it is a new application with new paperwork every five years.

The Minimum Tax Is Paid in Advance

The payment mechanics work as they did under the old programmes, and they still catch people out. Under rule 5(4), the minimum tax is due by 30 April of the year before the year of assessment. In Malta's system, the year of assessment follows the income year, so this means you pay the minimum during the year in which you earn the income, not a year later.

The payment goes in with a return that proves you still meet every condition in rule 4. If it is clear that your status will not be granted before 30 April in your first year, the minimum has to be paid before the grant. Rule 5(4)(c) is short and blunt: the minimum tax "shall not be refundable".

Missing the payment or the deadline is itself a ground for losing the status under rule 6(1)(k).

Who Can Apply, and Who Cannot

Rule 4 sets out the conditions. Some are familiar from the old programmes, some are new. An applicant must:

• hold a qualifying property holding and live in it as their primary residence, with only dependants and notified household staff living there;
• have stable and regular resources to support themselves and their dependants without Maltese social assistance;
• hold a valid travel document and sickness insurance covering all risks across the EU;
• not be domiciled in Malta and not intend to establish domicile within five years;
• be a fit and proper person;
• be able to communicate adequately in one of Malta's official languages, which in practice means English or Maltese.

The language test is new. So is a narrower rule on who may represent you. Every application must go through an "authorised registered mandatary", and under the new definition that is limited to warranted advocates, legal procurators, notaries and warranted accountants, or firms at least 75% owned by them. The old rules also admitted members of several professional institutes.

Nationality splits the categories. Global resident status is for third-country nationals who are not long-term residents. The EU, EEA and Swiss category is for those nationals who are not Maltese and not permanent residents of Malta. If you are unsure which side of that line your family sits on, the overview of the older programmes maps the same split.

The Permanent Residence Clause

One definition in rule 2 has consequences far beyond the application form. A "permanent resident of Malta" includes anyone who holds an EU permanent residence certificate, and also anyone who merely applies for one. A "long-term resident" likewise includes anyone who has applied for third-country long-term resident status.

Rule 6(1)(c) ends special tax status if you become either after your status is granted. Rule 5(5) then taxes such a person on worldwide income at Malta's normal rates. Your mandatary must check this for you and every dependant as at 31 December each year, and report to the Commissioner by 30 April. A mandatary who fails to report faces a €10,000 penalty.

For many families this creates a real choice. The residence routes that lead to permanence, covered in the guide to permanent residence routes, and the ITP's flat tax now pull in opposite directions. The Malta Permanent Residence Programme is a separate residence scheme and is not touched by L.N. 195; its current costs are in the MPRP guide.

Other Ways to Lose the Status

The cessation list in rule 6(1) is long. Beyond the permanent residence clause and missed payments, special tax status ends if you:

• become a Maltese national;
• stop holding the qualifying property, including by letting or subletting it;
• stay in any other single jurisdiction for more than 183 days in a calendar year;
• lose your private medical insurance;
• stop being represented by an authorised registered mandatary;
• fail to meet any other condition in rule 4.

There are also administrative penalties. A change in your dependants must be notified within four weeks, with a €5,000 penalty if you miss it. The same four-week window and the same penalty apply if you become aware that you no longer qualify. The Minister keeps a power to pardon a failure caused by circumstances beyond your control, provided you notify it and try to fix it.

The Retirement and UN Categories

The two pension categories get their own numbers.

Retired pensioner status carries a minimum tax of €15,000 a year. Pension income must make up at least 75% of the beneficiary's chargeable income and must all be received in Malta. Under the old Malta Retirement Programme Rules, the minimum was €7,500 plus €500 for each dependant, and the application fee was €2,500. The property thresholds for retirees rise in the same way as for everyone else.

UN pensioner status keeps the full exemption for the United Nations pension itself, provided at least 40% of it is received in Malta. Other foreign income is taxed at 15%, with a minimum of €20,000. Under the old UN Pensions Programme Rules, that minimum was €10,000, plus €5,000 if both spouses received a UN pension.

Any income that falls outside the 15% regime, in every category, is taxed as separate income at 35%.

The 31 December 2026 Line

The second proviso to rule 3(3) is the part to act on this year. Special tax status granted up to 31 December 2026, and any application received by that date, continues until 31 December 2031.

For an existing GRP or TRP holder, that means five more years on the €15,000 minimum and the old property thresholds, then a decision in 2031. For someone who has been weighing an application, it means the difference between a €15,000 floor and a €35,000 floor may depend on whether a complete file reaches the Commissioner before the end of December.

The rules do not say how applications made under the older rules after that date will be treated. Anyone who wants the old terms should plan to have the application in well before the deadline, with a property holding that already meets the old thresholds.

Is €35,000 Still Worth It?

The flat 15% rate only applies to foreign income you bring into Malta. For many people who are simply resident and not domiciled, the ordinary remittance basis already keeps unremitted foreign income out of Maltese tax. Article 56(27) of the Income Tax Act sets a minimum tax of €5,000 for non-domiciled residents with at least €35,000 of foreign income that is not fully remitted, and that route has no property threshold, no fee and no mandatary.

The comparison between the two paths is laid out in the piece on non-dom versus special tax status. The new numbers shift it further. A €35,000 floor only pays off when the remitted foreign income is large enough that 15% beats the ordinary progressive rates by more than the extra cost, or when a formal, documented status matters to you for reasons beyond the tax bill itself.

What to Do Before the Year Ends

If you are already a GRP, TRP or Retirement Programme beneficiary, nothing changes until 2031, but your obligations under the old rules continue. Keep your property holding, your insurance and your minimum tax payments in order, because a lapse now would push you onto the new terms.

If you are considering an application, three things decide whether 2026 is still realistic:

1. A qualifying property under the current thresholds, bought or rented, and used as your primary residence.
2. A mandatary who can file a complete application well before 31 December.
3. A clear view on permanent residence. If your family is heading towards an EU permanent residence certificate or long-term residence, the new rules will end the status the moment that application is made.

The Individual Tax Programme keeps Malta's 15% flat rate alive for another generation of applicants. It also makes it a product for a narrower group: people with substantial foreign income, a €700,000 home or a €14,000 lease, and no plan to become permanent residents.

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