# Malta GRP: special tax status, residence card and remittance basis > Malta's Global Residence Programme: special tax status, residence card and the remittance basis of taxation. Who qualifies and fit for UHNW relocation. Author: Мария Плотникова — юрист, Family Office (https://wiki.private.law/authors/plotnikova) Last modified: 2026-07-21T09:30:00.000Z Canonical: https://wiki.private.law/en/global-residence-program Topics: migration Jurisdictions: malta Functional tags: residence-permit, tax-regime Semantic tags: residence-permit, tax-regime --- 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. > 🍓 GRP gives a tax status and a residence card, but not Maltese or EU citizenship. A separate story: on 29 April 2025 the CJEU (case [C-181/23](https://curia.europa.eu/site/upload/docs/application/pdf/2025-04/cp250052en.pdf)) held Malta's citizenship-by-investment programme (MEIN) to be contrary to EU law — Union citizenship cannot be the object of a transaction. Act XXI of 2025 of 24 July 2025 abolished investor naturalisation; in its place is citizenship by merit for exceptional services, at the state's discretion. The "golden passport" for a payment no longer exists, and GRP never led to a passport in the first place. ## Regulatory context GRP is governed by the [Global Residence Programme Rules, 2013](https://legislation.mt/eli/sl/123.148/eng) 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). > ⚙️ GRP does not automatically release you from tax residence in your home country. If, under another country's domestic rules, a person remains its resident, dual residence arises — and it is resolved through the tax treaty, via the [tie-breaker](https://wiki.private.law/en/tax-residency-tiebreaker). ## 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 | **Income** | **Rate** | | --- | --- | | Foreign income remitted to Malta | **15%** flat | | Foreign income NOT remitted to Malta | **0%** (remittance basis) | | Malta-source income | Standard Maltese rates up to 35% | | 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 in the south/Gozo) | — | | Legal support | €10,000–18,000 | — | | 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 | | **Minimum setup (rental option)** | **€16,000–24,000** | **€29,000–37,000/year** | ## Frequently asked questions ### **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, minimum €16,000–37,000/year, no passport. **MEIN** (Maltese citizenship by investment) was formally closed on 26 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, MPRP (a €37,000 contribution to the state, property from €375,000 to purchase or €14,000/year to rent, a €2,000 charitable contribution) — 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, which entered into force on 26 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. ## 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](https://wiki.private.law/en/switzerland-residence-permit) (forfait); in Italy, the €200,000-a-year regime on all worldwide income; 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](https://wiki.private.law/en/uk-non-dom-2025) 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](https://wiki.private.law/en/cbi-egypt-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"](https://wiki.private.law/en/perpetual-traveler) logic, which has its own limits. > 🧭 If Malta does not fit on climate, language or budget, neighbours cover the same class of tasks: [Monaco](https://wiki.private.law/en/monaco-residence-permit) with zero income tax, [Gibraltar](https://wiki.private.law/en/gibraltar-residence-permit) with Category 2, [Andorra](https://wiki.private.law/en/andorra-residence-permit) with a low tax base, and [Switzerland](https://wiki.private.law/en/switzerland-residence-permit) with the lump-sum regime. Each has its own entry price and its own presence requirements. > 🍓 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) --- ## Sources - [C-181/23](https://curia.europa.eu/site/upload/docs/application/pdf/2025-04/cp250052en.pdf) - [Global Residence Programme Rules, 2013](https://legislation.mt/eli/sl/123.148/eng) --- ## FAQ ### 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, minimum €16,000–37,000/year, no passport. MEIN (Maltese citizenship by investment) was formally closed on 26 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, MPRP (a €37,000 contribution to the state, property from €375,000 to purchase or €14,000/year to rent, a €2,000 charitable contribution) — 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, which entered into force on 26 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. --- ## Factual claims - 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. - GRP is governed by the Global Residence Programme Rules, 2013 under Malta's Commissioner for Revenue. - Before 2013, Malta had several disparate schemes for wealthy foreigners — the Residents Scheme and the High Net Worth Individuals Scheme. - The closure of investor citizenship in 2025 reshaped the market.