The aim of the Highly Qualified Persons Rules is to establish a program designed to attract highly skilled individuals to fill “eligible positions” within companies licensed or recognized by regulatory authorities overseeing financial services, gaming, aviation, and reproductive technologies.
These positions are ones where there is insufficient supply of highly qualified Maltese individuals to meet industry demand.
Individuals earning income from a qualifying employment contract in an “eligible position” with a company licensed by the regulatory authority are subject to a flat tax rate of 15%, provided their income exceeds €98,436 for the 2024 tax year. The authority can only issue determinations of eligibility under this scheme until December 31, 2025. Those deemed eligible will be subject to the 15% flat tax rate until December 31, 2030.
To qualify for the scheme, in addition to meeting the minimum income requirement, highly qualified individuals must:
- Receive employment income subject to Maltese income tax.
- Hold an employment contract governed by Maltese law, demonstrating genuine and effective work in Malta to the satisfaction of the regulatory authority.
- Possess professional qualifications and have at least five years of professional experience.
- Fully disclose and declare all income for tax purposes, including income from related parties.
- Demonstrate engagement in activities of an eligible office.
- Show receipt of stable and adequate resources to support themselves and their families without reliance on Malta’s social assistance system, and meet residency, travel document, and insurance requirements.
The eligible positions include roles such as Actuarial Professional, Aviation Continuing Airworthiness Manager, Chief Executive Officer, and others listed in the provided document.
Highly qualified individuals in key positions within licensed entities in financial services, gaming, aviation, or reproductive technologies who wish to ascertain their eligibility for this tax scheme are encouraged to contact btonna@novo.legal.