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By virtue of Legal Notice 250 of 2025, published on 17 October 2025, the Minister responsible for finance has introduced the Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules, 2025 (the “Rules”). These Rules establish a targeted preferential tax regime applicable to qualifying senior employees engaged in eligible positions within Single Family Offices, Multi Family Offices, Back Office functions and Treasury Management Operations in Malta.
Through these Rules, Malta aims to attract experienced professionals in the financial services sector and ensure the system remains protected through strong anti-abuse measure.
Scope and Eligibility
The Rules apply to individuals earning income from a qualifying contract of employment in an eligible senior position, such as CEO, Managing Director, Head of Risk, Head of Compliance, Portfolio Manager, Senior Trader, or other roles listed in the Schedule.
The preferential 15% tax rate applies to income earned as from basis year 2025 (YA 2026), provided the following conditions are met:
- Earn at least €65,000 annually (indexed every five years).
- Hold relevant qualifications or professional experience.
- Have adequate accommodation and private health insurance in Malta.
- Not have previously benefited from another special tax regime.
- Be taking up their first employment in Malta in an eligible office after 1 January 2025.
- Be protected as an employee and perform genuine work.
- Fully disclose employment and related income for tax purposes.
- Demonstrate stable financial resources and suitable living arrangements.
- Comply with any additional conditions imposed by the competent authority.
Application Process
Applications may be submitted between the publication of the Rules and 31 December 2034, with the final acceptance deadline set at 31 December 2035.
Eligibility is determined by the Malta Financial Services Authority within 90 days of submission. Once eligibility is confirmed, the individual may elect to be taxed at a flat rate of 15% in terms of Article 56(21) of the Income Tax Act.
Tax Benefits
A flat tax rate of 15% applies to income derived from qualifying employment, up to a maximum of €7 million per annum. No deductions, reliefs or refunds are available, other than credits under Article 23 of the Income Tax Management Act.
The benefit is granted for an initial period of five years, extendable up to a maximum of 15 years if conditions continue to be met. The regime expires on 31 December 2040.
Anti-Abuse Measures
The Rules contain strict anti-abuse provisions. The Commissioner for Tax and Customs may:
- Request documentation to verify compliance;
- Deny or withdraw the benefit in cases of non-compliance or artificial arrangements; and
- Reassess tax under the ordinary rules where misuse is identified.
Applicants have recourse to the appeal procedures under the Income Tax Management Act.
Key Takeaways
The introduction of this special tax regime underlines Malta's continued efforts to attract senior financial professionals to support the development of its family office and financial services ecosystem, while ensuring that robust safeguards are in place to prevent abuse.The 15% flat tax regime, coupled with clear eligibility and compliance requirements, provides a structured and predictable framework for both individuals and family office operators considering Malta as a strategic location.
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.
