Global Residence Programme Rules
The Global Residence Programme has been introduced for individuals who are not nationals of the EU, EEA, or Switzerland and their scope is to set out favourable conditions for third country nationals who are granted Maltese residence. An individual may apply for a special tax status under the GRP Rules but he must prove to the satisfaction of the Commissioner of Revenue that the requirements as laid out in the rules have been satisfied.
- The applicant holds a “Qualifying Property Holding” which is defined as immovable property situated in Malta which was either purchased in Malta for a consideration of not less than €275,000, or in Gozo or the South of Malta for a consideration of not less than €220,000 or rented for not less than €9,600 per annum for a property situated in Malta or €8,750 for a property situated in Gozo or the South of Malta. In either case the applicant should occupy such property as his primary residence;
- The applicant is not a person who benefits under the Residents Scheme Regulations, the High Net Worth Individuals EU/EEA/Swiss Nationals Rules, the High Net Worth Individuals Non-EU/EEA/Swiss Nationals Rules, the Malta Retirement Programme Rules, the Qualifying Employment in Innovation and Creativity (Personal Tax) Rules or the Highly Qualified Persons Rules;
- The applicant is not a long-term resident of Malta, i.e. the applicant does not have a long-term resident status in terms of the Status of Long-term Residents (Third Country Nationals Regulations) nor has the person applied for the long-term resident status under the same Regulations;
- The applicant is in receipt of stable and regular resources which are sufficient to maintain himself and his dependants without recourse to the social assistance system in Malta;
- The applicant is in possession of a valid travel document;
- The applicant is in possession of sickness insurance in respect of all risks across the whole of the European Union normally covered for Maltese nationals for himself and his dependants, recognising also as dependant the person with whom the beneficiary is in stable and durable relationship;
- The applicant can adequately communicate in one of the official languages of Malta i.e. English or Maltese; and
- The applicant is a fit and proper person i.e. the individual must prove to be of good conduct and good morals, has no criminal record or disqualifications or censorship by professional or regulatory bodies and is not adjudged bankrupt by a competent Court or authority, amongst other criteria.
The above conditions must be satisfied on an ongoing basis.
Procedure for Application
An application for special tax status under these Regulations can only be submitted to the Commissioner of Revenue through the services of an Authorised Registered Mandatary (“ARM”). The ARM is tasked with submitting the application, and making certain declarations on behalf of the applicant, such as those stating that the applicant is in receipt of stable and regular resources, that the applicant is not domiciled in Malta, etc. The acknowledgement or request for more information of the application will be sent to the Applicant’s ARM.
The applicant represented by an ARM applies to the Commissioner of Revenue for special tax status under these rules by paying a non-refundable administrative fee of €6,000 upon application and in case the qualifying property is situated in the south of Malta a non-refundable administrative fee of €5,500 upon application.
An individual in possession of the special tax status under these rules would be subject to the following tax treatment in Malta:
- Income arising outside Malta should be subject to a flat tax rate of 15% only if remitted to Malta by the beneficiary, the beneficiary’s spouse and children, provided that a minimum amount of tax of €15,000 shall be paid by not later than 30th April of the year in which the income is received in Malta and must be accompanied by a return made to the Commissioner confirming that all conditions of the scheme have been satisfied.
- The above income if not chargeable on the flat rate of 15% shall be charged as separate income at the rate of 35%.
It is advisable that the individual in possession of the relevant special tax status certificate may not reside in any other jurisdiction for more than 183 days in any calendar year.
Localities for the purposes of the definition of “South of Malta”