From the UK to Malta in 2026: A Practical Guide to the Global Residence Programme and Maltese Tax Residence 

Author: Lidia Smirnienko

For UK nationals considering establishing residence in Malta, the Global Residence Programme (GRP) offers a framework through which eligible non-EU/EEA/Swiss nationals may obtain special tax status in Malta, subject to satisfying the applicable conditions. However, GRP beneficiary status, Maltese tax residence and the issue of a Malta Tax Residence Certificate are distinct concepts and should be considered separately.

Importantly, the GRP does not impose a fixed minimum number of days that a beneficiary must spend in Malta. The programme nevertheless contains continuing conditions, including that special tax status ceases if the individual stays in any other jurisdiction for more than 183 days in a calendar year. By contrast, Maltese tax residence is a question of fact and depends on the individual’s circumstances.

The following case study illustrates the principal steps and practical considerations for a UK national considering an application before the end of 2026, covering GRP eligibility, the application process, Maltese tax residence, the Malta Tax Residence Certificate and  Maltese tax considerations relating to salary and dividends received from a UK company.

Case Study: A UK National Moving to Malta

Consider a UK national who:

• intends to establish residence and, where appropriate, tax residence in Malta;
• is a shareholder and director of a UK company;
• receives employment income and dividends from that company;
• wishes to obtain special tax status under the GRP; and
• intends, once the relevant factual basis has been established, to apply for a Malta Tax Residence Certificate.

The individual’s UK tax residence position should be assessed separately under the applicable UK rules. Leaving the UK does not, by itself, determine when UK tax residence ceases. The UK Statutory Residence Test, and where relevant the split-year rules, should therefore be considered with an appropriately qualified UK tax adviser.

Whilst every case turns on its own facts, the following sequence provides a practical overview of the Maltese process.

Step 1: Initial Assessment of GRP Eligibility

The first stage is to assess whether the individual satisfies the eligibility conditions of the GRP and whether the programme is appropriate for their wider residence and tax objectives. This includes reviewing:

• nationality and immigration status, including that the applicant is a third-country national and not a Maltese, EEA or Swiss national or a long-term resident;
• eligibility under the GRP, including that the applicant is not a person benefiting under another listed special tax scheme, such as the Malta Retirement Programme Rules or the Highly Qualified Persons Rules;
• availability of stable and regular resources sufficient to maintain themselves and their dependants without recourse to the social assistance system in Malta;
• source and nature of income;
• intended timing and extent of presence in Malta;
• qualifying property arrangements, namely a property purchased for not less than €275,000 (€220,000 in Gozo or the south of Malta) or rented for not less than €9,600 per annum (€8,750 in Gozo or the south of Malta), occupied as the applicant’s primary residence;
• sickness insurance covering all risks across the whole of the European Union normally covered for Maltese nationals, for the applicant and their dependants;
• a valid travel document, the ability to communicate adequately in one of Malta’s official languages, and fit and proper status;
• tax residence objectives; and
• relevant cross-border tax considerations.

Where the applicant relocates to Malta but remains a shareholder, director or employee of a UK company, consideration should also be given to where employment duties are performed and where the company’s management and control is exercised. Performing employment duties from Malta may have Maltese tax implications for the individual, while exercising management and control from Malta may also have implications for the company’s tax residence or create other Maltese corporate tax considerations. These matters are fact-specific and should be considered in light of both Maltese and UK tax rules and the applicable double taxation treaty.

Step 2: Submission of the GRP Application

Once all supporting documentation has been gathered, the application is submitted, through an authorised registered mandatary, to the International & Corporate Tax Unit within the Office of the Commissioner for Tax and Customs, together with a non-refundable administrative fee of €6,000 (€5,500 where the qualifying property is an owned property in the south of Malta).

The application is then subject to due diligence. This stage generally takes approximately two months, the timeframe may vary depending on the circumstances of the application and whether any additional information or documentation is requested.

Step 3: Positive Due-Diligence Outcome and Completion of the GRP Requirements

If the due diligence process is successful, the Office of the Commissioner for Tax and Customs issues an Approval in Principle. This does not yet grant special tax status. Instead, it provides the applicant with up to twelve months to satisfy the remaining requirements.

These generally include obtaining qualifying property in Malta, and paying the annual minimum tax of €15,000. The minimum tax is payable in full, without apportionment, both in the year in which special tax status is granted and in the year in which it ceases; where it is evident that status will not be granted before 30 April, the minimum tax for that year must be paid before status is granted. Accordingly, the timing of confirmation can have a practical impact and should be considered alongside the applicant’s broader residence and tax planning.

Why Timing Matters: Applying Before the 2027 Changes

Applicants considering the GRP in late 2026 should take particular care with timing. Legal Notice 195 of 2026 introduced the Individual Tax Programme Rules (S.L. 123.221), which are due to come into force on 1 January 2027 and consolidate Malta’s existing special tax residence programmes into a new framework.

Under the transitional arrangements, special tax status granted on or before 31 December 2026, including on applications received by that date, shall continue to apply until 31 December 2031, subject to the applicable conditions. For new applicants from 1 January 2027, the new framework introduces materially different requirements, including a qualifying property threshold of €700,000 (purchase) or €14,000 per year (rental) anywhere in Malta or Gozo, an administrative fee of €8,500, a five-year renewable term and a €35,000 minimum annual tax for the global resident status.

Step 4: Confirmation of GRP Beneficiary Status

Once the applicable conditions have been satisfied, the Maltese tax authorities issue formal confirmation of the special tax status with a Maltese Tax Identification Number (TIN). The preferential GRP tax treatment applies from the year in which the special tax status is confirmed, subject to continued compliance with the programme conditions.

Step 5: Malta  Residence Card Application

Following confirmation of GRP status, the residence card application can be submitted.

Although processing times vary, applicants should generally allow at least two months for the residence cards to be issued.

Step 6: Establishing Maltese Tax Residence

Holding GRP special tax status does not, by itself, answer every question concerning factual tax residence. Maltese tax residence does not depend on nationality or civil status; it is a question of fact.

The Income Tax Act does not set a day-count test: it defines an individual “resident in Malta” as one who resides in Malta, except for such temporary absences as the Commissioner considers reasonable. In practice, an individual who is present in Malta for more than 183 days in a particular year will generally be regarded as tax resident in Malta for that year. However, the 183-day test is not the only basis on which residence may arise. Maltese tax guidance also provides that an individual who comes to Malta to establish their residence may become resident from the date of arrival, regardless of the duration of their stay in Malta during that particular year.

This distinction is particularly relevant to GRP beneficiaries because the programme itself does not impose a fixed minimum number of days that must be spent in Malta. A person’s factual tax residence must therefore be analysed separately from their programme status.

Step 7: Malta Tax Residence Certificate

A Malta Tax Residence Certificate (TRC) is separate from GRP special tax status and the residence card.

Where an individual has relocated to Malta with the intention of establishing residence, the application should be supported by evidence of their factual residence, such as physical presence, accommodation, local banking and expenditure, utility bills and other relevant personal and economic links with Malta.

While there is no prescribed waiting period, in practice allowing at least three months from the individual’s actual relocation to Malta may provide sufficient time to establish and document the factual circumstances supporting the application.

UK Company, Salary and Dividends: Cross-Border Tax Considerations

A UK national who continues to own or work for a UK company after establishing a base in Malta should consider more than the GRP itself. The location from which employment duties are performed, the individual’s role in management and decision-making, the source and receipt of salary and dividends, and the interaction of Maltese and UK tax rules may all be relevant.

In practice, for Maltese tax purposes, employment income is generally treated as arising where the employment duties are performed. Accordingly, where an individual performs their duties for a UK company from Malta, the related employment income will generally constitute Malta-source income, irrespective of where the employer is established or where the salary is paid. Such income would therefore fall outside the 15% GRP rate, which applies only to income arising outside Malta and received in Malta, and would be charged as separate income at 35% under the Global Residence Programme Rules.

Where employment duties are performed partly in Malta and partly outside Malta, an apportionment may be required depending on the circumstances. Accurate records of where duties are performed are therefore important. The Malta–UK double taxation treaty should also be considered, including its separate provisions governing employment income and directors’ fees and the availability of double taxation relief.

By contrast, dividends received from a UK company may constitute foreign-source income and may therefore qualify for the 15% GRP rate when remitted to Malta, subject to the applicable GRP conditions and minimum annual tax. Foreign-source capital gains are generally not taxable in Malta for individuals who are not domiciled or not ordinarily resident in Malta, even if remitted. However, the position should be considered separately where the company is managed and controlled from Malta, as this may have implications for the company’s Maltese tax residence and the resulting tax treatment.

These matters are fact-sensitive. Maltese advice should therefore be coordinated, where appropriate, with UK tax advice, particularly in relation to UK residence and split-year treatment, continuing UK-source income and any company-level implications arising from activities carried out from Malta, including where the company’s management and control is exercised.

Conclusion: Planning a Move from the UK to Malta in 2026

For UK nationals considering Malta, the GRP can provide an attractive special tax framework, but it should not be viewed as a substitute for a wider residence and cross-border tax analysis. GRP beneficiary status, immigration residence documentation, factual Maltese tax residence and a Malta Tax Residence Certificate are related but distinct matters.

The distinction is particularly important for individuals who remain connected to a UK company through employment, directorship or shareholding.

With the Individual Tax Programme Rules due to take effect from 1 January 2027, prospective applicants considering the current GRP framework should also take the transitional rules into account when planning an application in 2026.

Frequently Asked Questions

Is there a minimum stay requirement under the Malta Global Residence Programme?

The GRP does not impose a fixed minimum number of days in Malta. However, special tax status ceases if the beneficiary stays in any other jurisdiction for more than 183 days in a calendar year.

How long does the GRP application process take?

Due diligence generally takes approximately two months. Following an Approval in Principle, the applicant has up to twelve months to satisfy the remaining requirements, and residence cards generally take at least a further two months to be issued.

What is the minimum annual tax under the GRP?

Under the current GRP, the annual minimum tax is €15,000. For new applicants from 1 January 2027, the new framework introduces a €35,000 minimum annual tax for the global resident status. Applications received by the competent authority by 31 December 2026 may benefit from the existing €15,000 minimum annual tax under the transitional provisions until 31 December 2031, subject to approval and continued compliance.

Is salary from a UK company taxed at the 15% GRP rate?

Where employment duties are performed from Malta, the related income will generally be Malta-source income and would be charged at 35% rather than the 15% GRP rate. Dividends from a UK company may constitute foreign-source income and may qualify for the 15% rate when remitted to Malta, subject to the applicable conditions.