High Net Worth Individuals Scheme (HNWI) – EU/ EEA/ SWISS

22nd January 2015

High Net Worth Individuals (HNWIs) taking up residence in Malta may benefit from a special and favourable Malta Tax status and treatment and Tax Incentives. The High Net Worth Individuals Rules will run in parallel to the Global Residence Programme.

The Malta High Net Worth Individuals Rules- EU/ EEA/ Swiss National

High net worth individuals (HNWIs) taking up residence in Malta may benefit from a special and favourable Malta tax status and treatment as follows:

income arising outside Malta which is received in Malta would be chargeable to tax in Malta at the flat rate of 15% - subject to the payment of minimum tax;
income arising in Malta and capital gains realised in Malta would be taxable in Malta at the higher rate of 35%;
no Malta tax would be chargeable on income arising outside Malta which is not received in Malta;
no Malta tax would be chargeable on capital gains realised outside Malta even if these are received in Malta.

Eligibility - Malta HNWI Rules

A HNWI seeking to benefit from the favourable Malta tax treatment described above would be eligible to apply to the Malta tax authorities for confirmation of his/her special status as such provided that the following key conditions are satisfied (on an initial and ongoing basis):

The applicant acquires immovable residential property in Malta against consideration of at least €400,000 or leases such property against aggregate annual rental payments of at least €20,000. The property need not be acquired or leased at application stage.
The applicant and his/her family must occupy the above mentioned immovable residential property in Malta as their principal place of residence and no person other than the applicant and his/her family may reside in the said property.
The applicant must be in receipt of stable and regular resources which are sufficient to maintain him/herself and his/her dependants without recourse to the local social assistance system.
The applicant must be in possession of private health insurance which covers him/herself and his/her dependants in respect of all risks across the EU.
The applicant must not be domiciled in Malta or be a long-term resident.
The applicant must be a fit and proper person.
The applicant is subject to annual minimum Malta income tax payment of at least €20,000 plus an additional €2,500 per dependant.

Application for High Net Worth Individuals Rules

An application seeking confirmation of the special tax status of a HNWI must be submitted to the local tax authorities by an Authorised Registered Mandatory registered as such with the local tax authorities and engaged for the purposes by the applicant. CSB Group is registered with the local tax authorities as an Authorised Registered Mandatory and may assist you in the matter.

Double Taxation Relief - Malta High Net Worth Individuals Rules

A HNWI would also be entitled to relief of double taxation otherwise suffered on income arising outside Malta which is received in Malta. Such relief would be available in the form of unilateral relief (in terms of the Malta Income Tax Act) or, alternatively, under a treaty in force between Malta and the country of source of the relevant income.

Further Tax Considerations

Malta does not levy any wealth taxes or estate or such other duties. However, duty is chargeable in Malta upon any inter vivos or causa mortis transfer of immovable property when the document effecting the transfer is executed in Malta. For further information, kindly Contact Us