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Legal Notice 20 of 2026 introduced the Tax Treatment of Highly Skilled Individuals Rules ("Rules") that came into force on 1 January 2026. These Rules confirm Malta's approach to incentivising specialised foreign talent, replacing several tax regimes with a single, harmonised regime.
The new Rules consolidate and replace the following tax regimes ("Old Rules"):
- Highly qualified Persons Rules
- Qualifying Employment in Innovation and Creativity (Personal Tax) Rules
- Qualifying Employment in Aviation (Personal Tax) Rules
- Qualifying Employment in Maritime Activities and the Servicing of Offshore Oil and Gas Industry Activities (Personal Tax) Rules
- Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules
The Rules provide a preferential flat tax rate of 15% on qualifying employment income earned by eligible individuals engaged in regulated sectors.
The Rules set out eligibility criteria for new applications whilst also providing transitional provisions for eligible individuals who, as at 31 December 2025 qualified as beneficiaries under the Old Rules.
The below guide provides an overview of these new Rules.
Tax Treatment of Highly Skilled Individuals
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
