Highly Skilled Professionals

From the 1^st of January 2026, the Highly Skilled Individuals Rules have come in force, providing for the favourable tax treatment of highly skilled individuals. As of 2025, the following tax rules are no longer accepting any applications and will provide tax benefits up till 2030 as a year of assessment:

• Highly Qualified Persons Rules,
• Qualifying Employment in Innovation and Creativity (Personal Tax) Rules,
• Qualifying Employment in Aviation (Personal Tax) Rules,
• Qualifying Employment in Maritime Activities and the Servicing of Offshore Oil and Gas Industry Activities (Personal Tax) Rules or
• Senior Employees of Family Office, Bank Offices and Treasury Management Operations Tax Rules.

The aim of these new Rules is to continue attracting talent within sectors that are instrumental to Malta – financial services, gaming, maritime, aviation, oil and gas, science, technology, engineering and mathematics, and the medical sector.

Eligibility

The Highly Skilled Individuals Rules capture eligible offices (including CEO, Head Risk Officer, CFO, COO, Chief Information Officer, Head of Marketing, Portfolio Manager, Senior Trader, Odds Compiler Specialist and Senior Analyst amongst others) within entities licensed or authorised by the MFSA, MGA, Malta Enterprise, Office to the Chief Medical Officer to Government and Transport Malta. In order to benefit from these tax incentives, persons must have an employment contract which falls under an eligible office.

Such individuals must:

• earn a minimum taxable annual salary of EUR 65,000 (excluding fringe benefits),
• carry out work duties in Malta
• have protection under Maltese employment law as an employee
• be in possession of professional qualifications
• fully disclose all earnings and emoluments received under the employment contract
• prove that they perform the activities of an eligible officer
• have stable and regular resources which maintain them and their family without the need of the social assistance system
• resides in an accommodation in Malta which is up to health and safety standards
• be in possession of a valid travel document
• be in possession of private medical insurance; and
• not be domiciled in Malta.

The minimum salary requirement will be adjusted upwards by €10,000 every five years. Where an applicant was previously benefiting under one of the above-mentioned tax schemes, and the applicable threshold was below €65,000, the new tax rules provide for a staggered increase over the subsequent three years.

These thresholds are critical for individuals seeking the 15% preferential tax rate under Article 56(21) of the Income Tax Act. Notably, this 15% rate is final; it generally applies without the possibility of further relief, set-offs, or deductions, subject to specific statutory exceptions. The 15% preferential rate is capped at an annual income of €7 million. Any earnings exceeding this threshold will be subject to standard progressive tax rates.

The Application Process

Applications must be submitted to the competent authority. Once all requested documentation is provided, a decision is issued within 90 days.

Claiming the Benefit

Once a formal determination is issued, the tax benefits become available, although they cannot be applied retroactively to any year preceding 2027.

To exercise the benefit, the taxpayer must file a formal declaration. This declaration—which is a matter of public record—must be endorsed by the Authority and specify the relevant years of assessment. For the benefit to remain valid, the taxpayer must ensure all income is declared fully, correctly, and within the statutory filing deadlines.

Transition and Extensions

Individuals who were already benefiting from existing specialised tax programmes (as mentioned above) as of 31 December 2025 are eligible to transition into the Highly Skilled Individuals Rules. The benefit applies to income earned for five years from the date the formal determination is issued.

A two-year extension is available, provided the beneficiary continues to meet all regulatory requirements. The request for an extension must be filed in the year prior to the expiry of the initial five-year period.

Regardless of extensions, all benefits under this scheme will cease for income earned after 31 December 2040. No applications under these rules will be accepted after the 31^st of December 2036.

GTG is well-equipped to guide both employers and employees through these new Rules, providing expert advice on eligibility and comprehensive support throughout the application process.

For any additional information or assistance, please contact us at info@gtg.com.mt

Author: Dr Kimberley Blundell