Effective 1 January 2025, Malta is introducing a competitive tax regime designed to attract senior professionals engaged within family offices, back-office structures and treasury management operations. Established through Legal Notice 250 of 2025 under Article 56(21) of the Income Tax Act, the initiative strengthens Malta’s positioning as a prime jurisdiction for international wealth management and financial services.
Special Tax Status and Qualifying Income Thresholds
Eligible senior employees may elect to have qualifying employment income taxed at a flat rate of 15% up to an annual income ceiling of €7 million. Any income exceeding this amount will be taxed under the ordinary progressive Malta income tax rules. The regime requires a minimum annual base salary of €65,000, excluding fringe benefits, with this threshold increasing automatically by €10,000 every five years.
Eligible Offices
The regime targets senior professionals occupying strategic roles, including:
- Head of the Back Office, Chief Executive Officer, General Manager, Country Head, Managing Director or equivalent designation
- Chief or Head Risk Officer
- Chief or Head Compliance and Anti-Money Laundering Officer
- Chief or Head Risk Officer, including Fraud and Investigations Officer
- Portfolio Manager
- Chief or Head Investment Officer
- Senior Trader
- Senior Structuring Professional
Eligible Entities
Eligible entities include:
Single Family Offices
- Fund managers exempt under Investment Services Act regulations 3(1)(f) or 3(1)(t)
- Registered trustees investing in Notified PIFs
- Licence holders investing private wealth without raising external capital
Multi Family Offices
- Licence holders investing private wealth without raising external capital
Back Office and Treasury Management Providers
- Entities confirmed in writing by the competent authority as servicing the above offices
Eligibility Requirements
To qualify, the following additional conditions must be met:
- The individual must be resident in Malta, with adequate accommodation and private health insurance
- Must not be domiciled in Malta
- Must not have been employed in Malta under ordinary Article 4 income tax rules prior to 1 January 2025
- Not have previously benefited under Article 6 of the Income Tax Act (Investment Services and Insurance Expatriate Scheme)
- The employment must involve genuine and effective work in Malta, rather than a nominal title or advisory-only role
- Full disclosure of all employment income and related emoluments is required
Application Process and Timeframes
An application for a formal determination of eligibility under these Rules and Article 56(21) of the Act must be submitted in the form or manner required by the competent authority, in agreement with the Commissioner, and include all requested information and supporting documents.
Applications will be accepted from 1 January 2025 to 31 December 2034, with no new applications accepted after 31 December 2035. Once granted, the special tax status is valid for an initial five-year period and may be extended twice, each extension covering an additional five years. The preferential tax treatment will not apply to income earned beyond 31 December 2040.
Conclusion
Malta’s introduction of a 15% flat tax regime provides a compelling fiscal proposition for senior executives within family office, back office, and treasury management operations, as well as for the organisations employing them. By combining clarity, stability, and a competitive tax rate, the regime strengthens Malta’s appeal as a hub for high-value executive functions. Professional guidance is recommended to ensure compliance with the eligibility criteria and to optimise long-term planning.
How can NCMB help
At NCMB, we assist businesses and senior professionals by providing clear guidance on the practical and strategic implications of the 15% flat tax regime for senior family office, back office, and treasury roles. Our team can help organisations determine eligibility, assess the impact on remuneration structures, and ensure full compliance with the regulations. To explore how this regime could benefit your business or key executives, please contact our tax advisory team.
