The Revenue Publishes FAQs On DAC6/MDR

Malta has introduced a new Individual Tax Programme consolidating its existing residence schemes into a single framework effective January 2027. While maintaining the attractive 15% tax rate on foreign-source income, the programme introduces significantly higher economic thresholds and a five-year renewable status model, signaling a shift toward attracting genuine long-term residents willing to make substantial contributions to the Maltese economy.

Malta's remittance basis of taxation offers favorable treatment for individuals who are resident but not domiciled in Malta, taxing foreign-source income only when received in Malta while exempting foreign capital gains entirely.

Malta is consolidating its four existing tax programmes into a unified Individual Tax Programme framework, effective January 2027. The new rules introduce significantly higher annual tax thresholds, increased property requirements, and stricter application fees while maintaining the attractive 15% flat tax rate on foreign-sourced income remitted to Malta.

Malta's personal income tax system is grounded in progressive rates that apply to an individual's chargeable income, that is, total income after deductions, exemptions, and allowances. For the 2026 basis year...

The Government of Malta has published Legal Notice 188 of 2025 – the Final Income Tax Without Imputation Regulations, 2025, in relation to Article 22B of the Income Tax Act. Such legal notice provides companies and certain trusts with the option to elect for a final tax rate in lieu of the imputation system, that has long characterised Malta's corporate tax regime.

Malta's transfer pricing framework has evolved significantly with the introduction of formal Transfer Pricing Rules in 2022 and subsequent amendments. As the transitional period approaches its end in 2027, international businesses with related-party cross-border transactions must understand how these regulations affect their operations and what documentation requirements they need to meet to ensure compliance with OECD principles and arm's length pricing standards.

Malta has consolidated its special tax status schemes into a single framework effective January 2027, offering four distinct categories for foreign residents. Each category provides a flat 15% tax rate on foreign-source income remitted to Malta, with varying minimum annual tax obligations and eligibility requirements based on nationality and income source.

Malta has concluded over 80 double tax treaties with major trading partners worldwide to eliminate double taxation on both passive and active income.

In a January 2013 decision, the ECJ held that the exit tax on unrealized gains on companies and entities redomiciling from the Netherlands is in breach of the freedom of establishment.

Malta and Liechtenstein have signed a Treaty for the elimination of Double Taxation in New York on the 27 September 2013.