Malta has long competed for wealthy non-residents with a favourable tax regime, and the Global Residence Programme is its principal instrument for nationals from outside the EU. An applicant receives a residence permit and a special tax status under which foreign income is taxed only when the money is remitted to Malta. This is the classic remittance basis.
The programme is designed for those who live across several countries at once and want a European tax base without the obligation to spend half the year on site.
Concept
The Global Residence Programme (GRP) is Malta's tax-residence programme, available to nationals from outside the EU/EEA/Switzerland. It grants a Maltese residence card with the right to reside in Malta permanently, provided the tax and property requirements are met.
The tax logic: 15% flat on foreign income remitted to Malta; 0% on foreign income not remitted to Malta (remittance basis); a minimum tax payment of €15,000/year per family.
Regulatory context
GRP is governed by the Global Residence Programme Rules, 2013 under Malta's Commissioner for Revenue. The programme was reinstated in its current form after the 2013 reform.
Before 2013, Malta had several disparate schemes for wealthy foreigners — the Residents Scheme and the High Net Worth Individuals Scheme. The EU criticised them because the conditions for EU nationals and third-country nationals differed. The 2013 reform consolidated everything into two parallel programmes: The Residence Programme for nationals of the EU, EEA and Switzerland, and the Global Residence Programme for everyone else. The tax mechanics are identical; only the pool of applicants differs.
The status is set up once and holds as long as the conditions are met: the qualifying property is retained, the minimum tax is paid, and the annual return is filed. The programme is administered by the Commissioner for Tax and Customs; the application is submitted only through a licensed Maltese agent (Authorised Registered Mandatory).
Conditions
Property
Purchase: from €275,000 (central and northern Malta); from €220,000 in southern Malta or Gozo
Or rent: from €9,600/year (€8,750 in the south/Gozo)
Must be occupied as the primary residence—the principal place of abode worldwide (rule 2 of the GRP Rules); letting or sub-letting it ends the status (rule 6(1)(b)).
Tax
Minimum €15,000/year per family (including dependants).
Covers the first €100,000 of foreign remitted income. Above that — a 15% flat rate.
Non-Maltese income that is not remitted is not taxed (remittance basis).
Other conditions
- Not hold Maltese long-term resident status at the time of application
- Not be a beneficiary of another Maltese special programme
- Full health insurance in the EU
- Knowledge of Maltese or English
- Clean criminal record
Tax regime under GRP
| Income | Rate |
|---|---|
| Foreign income remitted to Malta | 15% flat |
| Foreign income NOT remitted to Malta | 0% (remittance basis) |
| Malta-source income | a flat 35%, not the progressive scale (rule 5(2) of the GRP Rules) |
| Capital gains foreign (not remitted) | 0% |
| Wealth tax / inheritance | 0% |
Remittance basis means: if a business generates income abroad (for example, dividends from a Singapore company or the profit of a Hong Kong Ltd) and that money stays in foreign accounts, there is no tax in Malta. Only what is remitted to Malta is taxed at 15%.
What GRP gives
- a residence card with the right to reside in Malta;
- access to the Schengen area (90 days in 180);
- accumulated residency — does NOT lead to Maltese citizenship;
- tax residence with a favourable remittance regime;
- proximity to Italy, Greece and North Africa;
- the citizenship-by-investment programme (MEIN) was closed by Act XXI of 2025 of 24 July 2025 — following the CJEU ruling of 29 April 2025; there is no longer a payment route to EU citizenship via Malta.
What it does not give
- Maltese citizenship or an EU passport;
- an automatic right to salaried employment in Malta (a separate permit is required);
- free movement like an EU citizen;
- access to the national healthcare system without private insurance;
- automatic release from tax residence in your home country.
Costs
| Item | One-off | Annual |
|---|---|---|
| Application fee, Commissioner for Revenue | €6,000; €5,500 only where the qualifying property is purchased in the south of Malta (rule 3(1); the reduction covers neither Gozo nor rented property) | — |
| Property purchase | from €275,000 (Malta) or €220,000 (Gozo or the south of Malta) | — |
| Or rent (alternative) | — | €9,600+/year |
| Minimum tax in Malta | — | €15,000/year |
| Health insurance | — | insurer's premium; sickness cover for all risks across the EU is a condition (rule 4(f)) |
| Accounting and tax filing | — | adviser's fee; the annual return is filed with the minimum tax by 30 April (rule 5(3)) |
GRP among European tax regimes
GRP is one of several European structures with a fixed tax on foreign income. In Switzerland it is the lump-sum tax (forfait); in Italy, the Art. 24-bis TUIR regime (Presidential Decree No. 917 of 22 December 1986; from 1 January 2027, Article 246 of the new Consolidated Income Tax Act, Legislative Decree No. 117 of 19 June 2026, Art. 377) — €300,000 a year on all foreign income for those transferring residence from 1 January 2026 (Article 1, paragraph 25 of Law No. 199 of 30 December 2025); earlier entrants keep their own figures — €200,000 for those who transferred residence after Decree-Law No. 113 of 9 August 2024 came into force (10 August 2024) and €100,000 for those who transferred before that date; in Greece, a comparable €100,000.
Cyprus keeps non-dom with no tax on dividends and interest, and in 2025 the United Kingdom wound down its century-old non-dom regime and replaced it with the FIG regime. Against this backdrop, Malta's 15% on remitted income and 0% on unremitted income look moderate — with no entry contribution of hundreds of thousands of euros. All of these regimes sit in one grid with rate, term, minimum stay and entry cost in special tax regimes for new residents, and the residence side of the same choice — GRP beside Malta's MPRP, the Italian, Greek and Portuguese routes and the capital-based residences of Andorra, Monaco and Switzerland — is compared in investor routes in Europe.
The closure of investor citizenship in 2025 reshaped the market. The payment route to an EU passport via Malta disappeared, but tax residence survived: Brussels pressed on the trade in citizenship, and this did not touch residence programmes. So GRP, Malta's MPRP and neighbouring Mediterranean residence permits remain workable, while citizenship by investment is now sought outside the EU — in the Caribbean, Egypt and Jordan.
The choice between such programmes usually comes down to two questions: how much time the applicant actually spends in the country and where the centre of their interests lies. GRP does not require living on the island, but it forbids spending more than 183 days in any other single country — otherwise that country will claim the applicant's tax residence. This makes the scheme akin to the literal version of the five flags theory — the "resident nowhere" — which has its own limits.
The essence of GRP is predictability: a fixed 15% on income brought to the island, 0% on what stays abroad, an English-speaking jurisdiction in the EU, and the freedom not to live on site. The programme does not lead to citizenship, and after 2025 that is settled for good. The economic case appears when foreign income runs into the hundreds of thousands of euros and can realistically be kept outside Malta.
When it fits and when it does not
Fits
- UHNW with international income who want a 15% remittance regime in the EU
- non-EU nationals who need Schengen access
- families able to spend 3–6 months/year in Malta
- an alternative to the Beckham Law for those not working in Spain
- English as the language — Malta is English-speaking
Does not fit
- those wanting a fast EU passport — after the 2025 CJEU ruling there is no payment route via Malta
- those in salaried employment in Malta (a work permit is required)
- a business with active operations in Malta and no foreign income
- non-HNW without the minimum €15,000 tax/year + rent/purchase
- candidates without a clean SoW (after the 2022 EDD)
Q/A
How many days must an applicant spend in Malta
GRP sets no minimum required stay in Malta. The rule is the reverse: an applicant may not spend more than 183 days during a calendar year in any other single jurisdiction — otherwise GRP status ceases (rule 6(1)(f)). A separate question is the position of the country of former residence: some states (for example, Germany) apply their own tax-residence criteria regardless of the Maltese status.
What is the difference between GRP and MEIN
GRP is a tax residency permit and gives no passport. The statutory floor is €15,000 of minimum tax a year plus rent from €9,600/year (€8,750 in Gozo or the south of Malta) under the Global Residence Programme Rules, 2013 (S.L. 123.148, L.N. 167 of 2013 as amended by L.N. 267 of 2014 and L.N. 69 of 2020). The one-off entry payment is the administrative fee of €6,000; the reduced €5,500 under rule 3(1) applies only where the qualifying property is purchased in the south of Malta — not on Gozo, and not on rented property. It should not be confused with the annual obligations.
MEIN (Maltese citizenship by investment) was formally closed on 24 July 2025 (Act XXI of 2025) following the CJEU ruling of 29 April 2025 (case C-181/23); there is no longer a payment route to a Maltese and EU passport.
For permanent residence by investment there is a separate programme, the MPRP. Under the Malta Permanent Residence Programme Regulations (S.L. 217.26) as amended by Legal Notice 146 of 2025, the mandatory payments are an administrative fee of €60,000 (€15,000 within one month of submission, €45,000 within two months of the letter of approval), a government contribution of €37,000 — the same whether the qualifying property is owned or rented — and a €2,000 donation to a registered philanthropic organisation, €99,000 in total, plus an administrative fee of €7,500 for each dependant other than the spouse, minor children and differently abled adult children. The property test sits on top: purchase from €375,000 or lease from €14,000/year. But this is a residence permit, not citizenship. GRP remains a tax-residence regime with no passport prospect.
What about Maltese citizenship after the CJEU ruling (2025)
On 29 April 2025 the CJEU (case C-181/23) held Malta's citizenship-by-investment programme (MEIN) to be in breach of EU law. The programme was formally closed by Act XXI of 2025, enacted on 24 July 2025. Only naturalisation for genuine exceptional services, at the state's discretion, remains. GRP (tax residence) is not affected by this ruling.
Can an applicant from a sanctioned or high-risk jurisdiction obtain GRP
The official GRP rules set a general nationality condition for qualifying non-EU/EEA/Swiss applicants. That condition alone does not establish whether a particular applicant is eligible under current programme, residence-permit and sanctions rules. Before committing to property or fees, an applicant should ask an Authorised Registered Mandatory to confirm the current GRP and residence-permit requirements for the applicant, including sanctions screening and source-of-funds evidence. Rules for other Maltese residence or investment programmes must be checked separately.
Is remote work permitted
A foreign employer does not by itself make salary foreign-source income. Under MTCA guidance, work physically performed in Malta generally produces employment income taxable there; any treaty exemption has separate conditions. GRP's 15% treatment applies to qualifying foreign-source income remitted to Malta, while Malta-source income is generally taxed at 35% under the programme. Work authorisation and the treatment of the actual duties should be confirmed before remote work from Malta begins.
What about citizenship after 7 years
Maltese naturalisation after long residence is theoretically possible, but it is markedly discretionary and approvals are rare. The "passport by investment" channel into the EU is effectively closed: Cyprus (2020), Bulgaria (2022), and Malta's MEIN was held unlawful by the CJEU in April 2025. There is currently no payment route to EU citizenship.