Highly Skilled Individuals

Malta’s 2026 Highly Skilled Individuals Framework:

A Regulatory Talent Strategy for the Next Decade

Malta has introduced a new, consolidated framework for attracting senior international talent. Enacted through the Tax Treatment of Highly Skilled Individuals Rules, 2026 (L.N. 20 of 2026), this new framework consolidates several former incentive schemes, including the Highly Qualified Persons (HQP) Rules and the Qualifying Employment in Innovation and Creativity Rules, into a single, streamlined tax regime.

This is not simply a tax incentive. It is a regulatory-led talent strategy, designed to channel expertise into industries that are critical to Malta’s long-term economic positioning.

A unified and future-proof regime

Effective from 1 January 2026, the new framework establishes one set of eligibility standards and one tax treatment model for highly skilled professionals working in Malta.

The regime applies until 31 December 2040, offering long-term certainty for both employers and internationally mobile executives. It introduces defined qualification, role-based, and compliance requirements, to ensure that only genuine, high-value employment roles benefits from the incentive.

The fiscal incentive

Eligible beneficiaries may elect to be taxed at a flat rate of 15% on qualifying employment income, subject to:

Any income exceeding the €7 million cap is taxed under the standard rates that would otherwise apply.

Eligibility is role-driven, not salary-driven

A central feature of the 2026 framework is that the role itself must qualify.

An individual may only benefit if they hold an “eligible office” with an undertaking that is licensed or recognised by a statutory competent authority named in the rules.

These competent authorities are:

Malta Financial Services Authority

• for eligible offices within licensed or recognised financial services undertakings;

Malta Gaming Authority

• for eligible offices within licensed gaming operators;

Transport Malta, in relation to:

• aviation undertakings holding Air Operator Certificates or aerodrome licences
• maritime undertakings holding ISM or MLC certification
• shore-based ship management and offshore oil & gas servicing companies

The Office of the Chief Medical Officer to Government

• in respect of highly skilled medical and healthcare roles;

Malta Enterprise

• covering recognised strategic, innovation-driven and STEM-based industries.

This structure makes the regime a sector-specific tool, not a general expatriate tax programme.

Who qualifies?

To benefit, an individual must:

• Be non-domiciled in Malta
• Derive qualifying employment income in Malta
• Hold an eligible office within a licensed or recognised undertaking
• Earn at least €65,000 per year (excluding fringe benefits)
• Possess recognised qualifications or professional experience
• Be protected as an employee under Maltese law
• Hold private medical insurance and maintain normal accommodation in Malta

Substance is essential. Artificial job titles, restructured remuneration, or collusive arrangements are expressly targeted by anti-abuse provisions.

Duration and certainty

Initial term           ->        5 years

First renewal       ->        +5 years

Second renewal       ->    +5 years

Maximum benefit    ->    15 years

Up to                       ->      31 December 2040

Even with renewals, no benefits apply to income earned after the 2040 cut-off.

Strategic significance

The 2026 framework supports Malta’s wider economic strategy by directing highly skilled talent into regulated and growth-focused industries that are critical to the country’s long-term development. It gives employers a compliant, long-term tool to attract international expertise, while offering senior professionals a stable and competitive base within the European Union.

How Brainston can help

Brainston guides employers and professionals through every stage of the Highly Skilled Individuals framework, from eligibility assessment to application and compliance.

If you are considering this regime, contact Brainston for tailored advice and support.

Contact us

📞 +356 2152 1025/6

✉️ info@brainston.mt