Malta's New Tax Regime For Senior Professionals In Family Offices And Associated Sectors

Malta has introduced the Senior Employees of Family Offices, Back Offices, and Treasury Management Operations Tax Rules, 2025 (the "Rules"). Effective from the 1st of January 2025 and applicable as from the 2026 year of assessment, the Rules provide a highly competitive flat tax rate of 15% on qualifying employment income earned by eligible senior executives.

This measure forms part of Malta's broader strategy to strengthen its position as a leading European jurisdiction for family offices, private wealth structures, and treasury operations.

Understanding Family Offices

A family office is a private structure established to manage the financial and personal affairs of one or more high-net-worth families. Its primary objective is the preservation, growth, and intergenerational transfer of wealth.

Typical services include:

• Investment management;
• Estate and succession planning;
• Philanthropic structuring;
• Governance and lifestyle management;
• Family offices generally operate in two principal forms:
• Single Family Offices (SFOs) – Single Family Offices serve one family and typically manage private wealth without raising external capital. They may operate through exempt structures, including Notified Professional Investor Funds (PIFs);
• Multi Family Offices (MFOs) – Multi Family Offices serve multiple unrelated families and may require licensing for certain regulated activities, depending on the services provided.

Key Benefits of the Regime

Under the new framework:

• Qualifying income derived from an eligible employment contract is taxed at a flat rate of 15%;
• A minimum annual income threshold of €65,000 (excluding fringe benefits) applies;
• This minimum threshold will increase by €10,000 every five years from the entry into force of the Rules
• The 15% rate applies to annual emoluments up to €7,000,000;
• Any income exceeding this cap is subject to Malta's standard progressive income tax rates.;
• The benefit is granted for an initial period of five years, subject to renewal in accordance with the Rules.

Eligibility Criteria

Eligibility is subject to determination by the Malta Financial Services Authority (MFSA), acting as the competent authority.

To qualify, individuals must satisfy stringent conditions, including:

• Deriving income from a qualifying employment contract for work physically performed in Malta;
• Having no prior Maltese-sourced employment or business income under Articles 4(1)(a) or (b) of the Income Tax Act before 1 January 2025;
• Holding appropriate professional qualifications (at least three years of post-secondary education) or possessing five years of relevant professional experience;
• Performing genuine and effective duties under Maltese employment law and possessing the necessary competence for the role;
• Not being domiciled in Malta;
• Demonstrating sufficient and stable financial resources to support themselves and their dependants without recourse to social assistance;
• Holding suitable accommodation in Malta;
• Possessing a valid travel document and private health insurance covering all family members;
• Fully disclosing all relevant income, including income from related parties, for Maltese tax purposes.

Eligible Positions and Entities

The regime is specifically designed to attract senior professionals occupying key leadership and technical roles, including:

• Head of Back Office, Chief Executive Officer, General Manager, Country Head, Managing Director or equivalent designation;
• Chief Risk Officer or Head of Risk;
• Chief Compliance Officer or Head of Compliance and Anti-Money Laundering;
• Fraud and Investigations Officer;
• Portfolio Manager;
• Chief Investment Officer or Head of Investments;
• Senior Trader;
• Senior Structuring Professional.

These roles must be held within:

• Single Family Offices, including fund managers or registered trustees exempt from investment services licensing requirements and managing private wealth without raising external capital;
• Multi Family Offices licensed to manage wealth for multiple high-net-worth families without raising external capital;
• Back-office or treasury management undertakings servicing the above entities, as confirmed in writing by the MFSA.

Application and Renewal Process

Applications for eligibility must be submitted to the MFSA between:

• 1 January 2025 and 31 December 2034;
• No applications will be accepted after 31 December 2035.

The MFSA is required to process applications within 90 days, although additional information may be requested during the review process. Upon approval, the determination is endorsed by the Commissioner for Tax and Customs.

Beneficiaries may then opt for the 15% tax rate by submitting a signed declaration, effective from the 2026 year of assessment.

An application for renewal must be submitted during the year preceding the end of the relevant five-year qualifying period, whether this relates to the first or second qualifying period.

Conclusion

The Senior Employees of Family Offices, Back Offices, and Treasury Management Operations Tax Rules, 2025 represent a deliberate and strategic initiative aimed at enhancing Malta's competitiveness in the global private wealth landscape.

By combining a competitive 15% flat tax rate with clearly defined eligibility criteria and robust regulatory oversight, the regime balances fiscal attractiveness with substance and compliance requirements. It offers certainty to internationally mobile senior professionals while reinforcing Malta's standing as a transparent and well-regulated financial centre.

For family offices and associated service providers seeking to establish or expand their European footprint, this framework provides both operational efficiency and tax competitiveness. In doing so, it further consolidates Malta's position as a forward-looking and credible hub for global private wealth management.

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.