Highly Qualified Persons Rules (HQPR)

Intended applicants: Highly qualified persons occupying a role of “eligible office” with companies licensed and / or recognized by the Malta Financial Services Authority, companies licensed by the Malta Gaming Authority and undertakings holding an Air Operators’ Certificate or an Aerodrome License issued by Transport Malta, and earning a minimum of €84,991 per annum (for the year 2019).

Main conditions for eligibility:

  • Income must be derived from a qualifying contract of employment, with the minimum yearly income set at €84,991 (revised annually in line with the Retail Price Index).
  • The beneficiary must hold one of the senior management positions considered to be an ‘eligible officer’ by the tax department.
  • EEA / Swiss nationals may benefit under the scheme for a consecutive period of 5 years which will run from the first year in which the applicant becomes taxable in Malta. A one-time extension may be granted for a further qualifying period of 5 years.
  • Individuals who are not EEA / Swiss nationals of may benefit under the scheme for a consecutive period of 4 years which will run from the first year in which the applicant becomes taxable in Malta.
  • Must be in possession of sickness insurance (which must also cover any dependents).
  • The benefit is not available to an individual employed directly or indirectly by a company in which he / she holds more than 25% shareholding.
  • The beneficiary must not be domiciled in Malta.

Tax treatment:

  • Flat rate of tax of 15% on income derived from a qualifying contract of employment. This is imposed on income up to a maximum of €5 million, over and above which income will not be subject to tax in Malta.
  • Any rights are withdrawn with retrospective effect if a beneficiary is a third country national who stays in Malta for more than 4 years in aggregate, or who acquires (directly or indirectly) rights over immovable property situated in Malta.

For further detailed information, please send us an email on [email protected].

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