Global Residence Programme

A. Muscat, 12 Jul 2015

The Maltese Government introduced the Global Residence Programme in July 2013 aimed at granting Maltese residence to wealthy individuals who are not nationals of the EU, EEA or Switzerland. (For the Residence Programme which applies to nationals of the EU, EEA or Switzerland please click here)

Tax treatment

Under the GRP the beneficiary and his/her dependants pay merely 15% on the income earned abroad but received or remitted to Malta. This rate applies when the minimum amount of tax paid in Malta by the beneficiary and his/her dependants is at least EUR 15,000 after considering any double tax relief which they may be entitled to. This minimum tax requirement is payable in respect of income arising outside Malta, i.e. foreign sourced income. Other Maltese sourced income received by the beneficiary or his/her dependents, will be taxable at a flat rate of 35%.

Dependents

Dependent persons include the spouse, any children (natural, adopted or in care) under the age of 25, dependent brothers, sisters and direct relatives in an ascending line. The GRP also considers employees of the beneficiary such as carers and other persons that may have been employees of the applicant for the preceding two years, as eligible dependants.

Immovable property requirements

To qualify for this scheme, the beneficiary needs to either own or rent a qualifying owned property or qualifying rented property and occupy this as his principal place of residence worldwide. Qualifying owned property or qualifying rented property has to satisfy the following minimum values:

Owned property
  1. Immovable property situated in Malta other than in the south of Malta: €275,000
  2. Immovable property situated in the south of Malta: € 220,000
  3. Immovable property situated in Gozo: €250,000
Rented:
  1. Immovable property situated in Malta other than in the south of Malta: €9,600 per annum
  2. Immovable property situated in the south of Malta: € 8,750 per annum
  3. Immovable property situated in Gozo: € 8,750 per annum

The lease needs to be taken out for not less than a twelve month period.

Localities that are considered to be in the south of Malta, for the purposes of the GRP are: Birzebbugia, Bormla (Cospicua), Fgura, Ghaxaq, Gudja, Kalkara, Kirkop, Luqa, Marsascala, Marsaxlokk, Mqabba, Rahal Gdid (Paola), Qrendi, Safi, Santa Lucija, Senglea, Siggiewi, Tarxien, Birgu (Vittoriosa), Xghajra, Zabbar, Zejtun and Zurrieq.

It is strictly prohibited for any other person other than the beneficiary and his/her dependants or household staff to reside in the qualifying property at any time. In addition, the qualifying property may not be let or sub-let.

Other requirements

The beneficiary needs to satisfy the following requirements in addition to the Immovable property requirement specified above:

  • is not an EU, EEA or Swiss national;
  • is not a person who benefits under the Residents Scheme Regulations, the High Net Worth Individuals Rules, the Malta Retirement Programme Rules, the Global Residence Programme Rules, the Qualifying Employment in Innovation and Creativity Rules or the Highly Qualified Persons Rules;
  • 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;
  • is in possession of a valid travel document;
  • 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;
  • can adequately communicate in English or Maltese; and
  • is a fit and proper person.

No minimum stay requirements

Although there is no minimum amount of days that the person is required to be in Malta, the beneficiary cannot by in any other jurisdiction for a cumulative period of 183 days in a year.

Application Costs

A non-refundable administrative fee needs to be paid in respect of any application for special tax status in terms of the GRP. The administrative fee is that of EUR 6,000 except where the qualifying owned property is situated in the south of Malta, in which case the administrative fee is that of EUR 5,500.

For more information refer to the Inland Revenue Department dedicated web page.




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