Wiki / Residency & citizenship / Malta GRP: special tax status, residence card and remittance basis

Malta GRP: special tax status, residence card and remittance basis

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. The idea is simple: an applicant receives a residence permit and a special tax status under which foreign income is taxed only when the money is remitted to the island. This is the classic remittance basis in a Mediterranean wrapper.

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. Below: how the conditions, rates and costs work, how GRP differs from the investor citizenship that Malta closed in 2025, and where the scheme has its limits.

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 the principal place of residence in Malta; may not be sub-let.

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

IncomeRate
Foreign income remitted to Malta15% flat
Foreign income NOT remitted to Malta0% (remittance basis)
Malta-source incomea flat 35%, not the progressive scale (rule 5(2) of the GRP Rules)
Capital gains foreign (not remitted)0%
Wealth tax / inheritance0%

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

ItemOne-offAnnual
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€220,000–500,000+
Or rent (alternative)€9,600+/year
Minimum tax in Malta€15,000/year
Health insurance€2,000–5,000/year
Accounting and tax filing€3,000–8,000/year

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.

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 you actually spend in the country and where the centre of your 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 your residence. This makes the scheme akin to the "resident nowhere" logic, which has its own limits.

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 you spend in Malta

GRP sets no minimum required stay in Malta. The rule is the reverse: you may not spend more than 183 days during a calendar year in any other single jurisdiction — otherwise GRP status may be lost. Actual presence in Malta for most beneficiaries is 90–150 days/year, but this is practice, not a statutory requirement. A separate question is the position of the country of former residence: some states (for example, Russia, 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 a Russian national obtain GRP

Legally — yes. In practice, after 2022, enhanced due diligence applies: expanded SoF/SoW, no sanctions connection, ESG parameters. Some applications from Russian UBOs were rejected in 2022–2024. Since 2025 there has been a gradual return to the standard procedure for a clean profile.

Can you work remotely

Yes, if the employer is not in Malta. Income from foreign employment is foreign income under the remittance basis. Only what is remitted to Malta is taxed at 15%. The regime applies to remote professionals and wealthy clients with a foreign source of income: foreign employment qualifies as foreign income under the remittance basis.

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.

Download the offer «Malta Global Residence Programme»

How we approach such matters, the stages, the team and the contacts in one short document.

If you have questions or need a consultation, our experts will be glad to help.

Request a callback

Your contacts are used to answer this request. No mailing lists.