Highly Qualified Persons Programme

Special Tax Rates

An individual who has been granted this special tax status will be subject to tax at a flat rate of 15% on income derived from a qualifying contract of employment.

Conditions to satisfy 

• The individual is not domiciled in Malta;
• The individual receives income, being emoluments payable under a qualifying contract of employment, and received in respect of work or duties carried out in Malta;
• He is protected as an employee under Maltese Law, has adequate and specific competence, and is in possession
  of professional qualifications;
• He is not a person who has benefitted under Article 6 of the Income Tax Act (Investment Service and Insurance Expatriate);
• The individual fully discloses for tax purposes and declares emoluments received in respect of income from a qualifying contract of employment;
• He proves that he performs activities of an eligible office.

Minimum Tax Requirement

Beneficiaries who qualify and receive a minimum employment income may benefit from such special tax rate. The minimum income (revised annually in terms of the Retail Price Index published by the NSO) is set at €98,436 for basis year 2024.

Eligible office

"Eligible office" in the financial services and gaming sectors (and undertakings holding an air operators certificate) comprises employment in one of the following positions:

• Actuarial Professional
• Aviation Continuing Airworthiness Manager
• Aviation Flight Operations Manager
• Aviation Ground Operations Manager
• Aviation Training Manager
• Chief Executive Officer
• Chief Financial Officer
• Chief Commercial Officer
• Chief Insurance Technical Officer
• Chief Investment Officer
• Chief Operations Officer (including Aviation Accountable Manager)
• Chief Risk Officer (including Fraud and Investigations Officer)
• Chief Technology Officer
• Chief Underwriting Officer
• Head of Investor Relations
• Head of Marketing (including Head of Distribution Channels)
• Head of Research and Development; (including Search Engine Optimisation and Systems Architecture)
• Portfolio Manager
• Senior Analyst (including Structuring Professional)
• Senior Trader/TraderOdds Compiler Specialist

"Eligible office" in an aerodrome licensed undertaking refers to employment in the following position:

•  Chief Executive Officer

 "Eligible office" in the assisted reproductive technology sector comprises employment in one of the following positions:

•  Embryologist
• Responsible Person
• Lead Quality Manager

Tax Implications

Income received from a qualifying contract of employment be taxed at a flat rate of 15%. No further tax would be charged
on income from a qualifying contract of employment in excess of €5,000,000. Any other income, that is chargeable to tax in Malta, will be subject to tax at the rate of 35%.

Annual Compliance

• Filing an annual income tax return;
• Filing of an annual declaration signed by the beneficiary and endorsed by the related authority.

How can Mazars help 

We provide both national and international tax advice to a diverse global client base. We work with global privately-owned businesses and European listed companies, but also with local companies, and private individuals.

Should you need any assistance in understanding your tax implications, do not hesitate to contact us.