Malta has been on the EU’s short list of tax destinations for years thanks to its «resident non-domiciled» regime, conceptually similar to the one the UK held for two centuries: you’re taxed on Maltese-source income and on whatever you bring (remit) into Malta from abroad, but not on foreign income you keep outside Malta. What changed in 2025 is that «not paying tax» now has a minimum floor that didn’t exist before.
How you qualify for non-dom status
You need to be a Maltese tax resident — 183 days a year, or maintaining your habitual home there — without having Malta as your country of domicile of origin (a common-law concept, different from nationality or residency, that in practice is inherited from your father or acquired through clear intent of permanent settlement). Most foreigners moving to Malta meet this condition without difficulty: domicile of origin is, almost always, where you were born or where your family has its legal origin, not where you currently live.
The 2025 change: a minimum tax that didn’t exist before
Since 2025, an ordinary resident non-domiciled in Malta who isn’t enrolled in any special programme (like the GRP or TRP, see below) is subject to a minimum annual tax of €5,000, provided their worldwide foreign-source income exceeds €35,000 a year. Before this change, someone with high foreign income who simply didn’t remit it to Malta could, in practice, come close to a very low effective tax rate with no floor at all. That margin has narrowed, not disappeared entirely, but now has a concrete figure attached.
The special programmes: GRP and TRP
For those seeking something more structured than the general non-dom regime, Malta offers programmes like the GRP (Global Residence Programme) and the TRP (The Residence Programme), which tax foreign income remitted to Malta at a flat 15%, with a minimum annual tax of €15,000. In exchange for that higher floor than the general regime, these programmes don’t require a fixed number of days of stay like Cyprus’s 60-day rule — they require Malta to be your main residence, understood as not spending more than 183 days in any other single country, with no fixed minimum number of days in Malta itself.
Maltese income vs. foreign income: the distinction that decides everything
Maltese-source income is always taxed in Malta, at the general progressive rates (0% to 35%), whether remitted or not. Foreign-source income is only taxed if you remit it to Malta — and here’s the nuance that causes the most confusion: foreign-source capital gains, unlike ordinary income, aren’t taxed in Malta even if remitted. It’s a deliberate asymmetry in the Maltese system that sets it apart from other remittance regimes, and it’s worth understanding well before deciding what to bring into Malta and what to leave outside.
In the comments: if you’re non-dom in Malta, share how you handle the distinction between ordinary income and foreign capital gains when deciding what to remit, and whether the 2025 minimum tax has affected you in practice. It’s the kind of nuance only someone actually living it can really explain.
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Sources: Malta Tax and Customs Administration (remittance basis guidance), tax guides updated for 2026 (CSB Group, ImmigrantInvest, Freenance). This isn’t tax advice — the «domicile of origin» determination and the minimum tax’s application depend on specific facts worth reviewing with a Maltese adviser.