Malta residency and citizenship: Three key reforms for 2026–2027

Tax residence: a new consolidated programme

From 01 January 2027, Legal Notice 195 of 2026 brings Malta’s special tax residence schemes, including the Global Residence Programme (GRP) and The Residence Programme (TRP), under a new Individual Tax Programme.

Currently, TRP caters for European Union, European Economic Area (EEA), and Swiss nationals, while GRP generally applies to other nationals. Beneficiaries may enjoy a 15% tax rate on qualifying foreign income remitted to Malta, subject to a minimum annual tax of EUR 15,000.

The new programme retains the 15% rate but introduces higher minimum tax, property thresholds, and application fees, together with a five-year renewal cycle. Timing matters: applications submitted by 31 December 2026 may retain the current framework through 2031.

For US and Canadian citizens, Malta’s rules determine Maltese taxation only; home-country obligations remain subject to domestic rules and applicable tax treaties.

Citizenship: Legislative changes

Following the Court of Justice of the European Union’s judgment of 29 April 2025, Malta revised its citizenship framework in July 2025. The investment-linked route was repealed, and Citizenship by Merit under Article 10(9) of the Citizenship Act is now Malta’s sole legal basis to exceptional naturalisation, it is a discretionary grant reserved for individuals who demonstrate an exceptional contribution to Malta or humanity in fields such as science, philanthropy and economic development. The framework also requires a genuine footprint in Malta, including at least eight months of residence preceding the naturalisation application.

Permanent residence: greater flexibility

For non-EU nationals, the Malta Permanent Residence Programme (MPRP) remains an attractive route to permanent residence in Malta, with Schengen travel of up to 90 days in any 180-day period.

Following Legal Notice 146 of 2025, applicants may obtain a one-year temporary residence permit while their permanent residence application is processed.

The programme requires government contributions and fees, qualifying property through purchase or lease, and a philanthropic donation, with no minimum annual physical stay requirement.

Why timing matters

These three changes serve different objectives. The right solution depends on nationality, tax position, family circumstances, and long-term plans. With transitional provisions applying during 2026, timing can make a real difference. For those considering Malta, now is an ideal time to assess the available options and identify the route best suited to their objectives.

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Kevin Mifsud is the CEO of KMFinco Audit & Assurance Ltd. A GGI member since 2004, Kevin advises international clients on audit, taxation, advisory, and business matters, bringing together technical expertise, commercial insight, and a pragmatic, solutions-driven approach.