The Residence Programme (TRP)
The Residence Programme (TRP) is Malta’s special tax status programme for EU, EEA and Swiss nationals. It provides a structured route to a favourable flat rate of tax on foreign-source income remitted to the island -making it one of the most tax-efficient residence options available to European and Swiss nationals within the EU framework.
The TRP was introduced to mirror the benefits available to third-country nationals under the Global Residence Programme (GRP), extended to EU, EEA and Swiss citizens. Individuals previously granted special tax status under the predecessor High Net Worth Individuals (HNWI) Rules and the Permanent Residence Permit (PRP) before that may apply to transition to TRP status.
GVZH Advocates is an Authorised Registered Mandatory licensed with the International & Corporate Tax Unit, and advises on the full process from eligibility assessment through to application, approval and ongoing annual compliance.
Main Benefits of The Residence Programme
Approval under the TRP and application for a residence card thereafter, entitles the main applicant and qualifying dependants to a Maltese residence permit, giving the family the right to reside in Malta and travel freely within the Schengen Area without the need for a separate Schengen visa.
The programme’s core advantage is tax efficiency. Foreign-source income remitted to Malta is subject to a special flat rate of 15%, with the possibility of claiming relief under Malta’s extensive network of double taxation agreements. Foreign-source income not remitted to Malta falls entirely outside the Maltese tax net.
The TRP also provides access to a stable, government-backed residence status that does not require employment in Malta and is not tied to any investment vehicle. For EU, EEA and Swiss nationals seeking a primary residence within the EU on favourable tax terms, it remains one of the most straightforward available routes.
Eligibility Requirements
An individual is eligible to apply under The Residence Programme if all of the following conditions are met:
- The applicant is an EU national (excluding Maltese nationals), EEA national, or Swiss national
- The applicant does not currently benefit under the Residents Scheme Regulations, the HNWI Rules (EU/EEA/Swiss or Non-EU/EEA/Swiss), the Malta Retirement Programme Rules, the Qualifying Employment in Innovation and Creativity Rules, or the Highly Qualified Persons Rules
- The applicant holds or rents qualifying residential property in Malta meeting the following minimum thresholds:
- Purchase: not less than €275,000 (Malta); reduced thresholds apply for properties in Gozo or the South of Malta
- Rent: not less than €9,600 per annum (Malta); not less than €8,750 per annum (Gozo or South of Malta)
- The qualifying property must serve as the applicant’s primary residence in Malta and may not be shared with individuals who are not listed dependants on the TRP certificate (an exemption applies for special carers)
- The applicant holds comprehensive health insurance covering themselves and all dependants for all risks across the entire European Union
- The applicant satisfies a fit and proper assessment -a due diligence exercise is carried out by the Malta International and Corporate Tax Unit prior to the granting of special tax status
- The applicant can communicate adequately in English or Maltese
- A non-refundable application fee of €6,000 is payable upon submission (a reduction applies for properties in Gozo or the South of Malta)
- The main applicant must pay a minimum annual tax of €15,000
Tax Treatment in Detail
The tax position under the TRP is straightforward but requires careful planning to ensure it is properly established and maintained:
- Foreign-source income remitted to Malta is taxed at a fixed rate of 15%, with double tax relief available under applicable treaty arrangements
- The minimum annual tax liability is €15,000, regardless of the amount of income remitted
- A TRP beneficiary and their spouse may not elect for a separate tax computation
- Foreign-source income not remitted to Malta is not subject to Maltese tax
- Income arising in Malta is taxed at 35%
Tax residence under the TRP and the availability of the special rate depends on the correct structuring of income sources and remittances. GVZH’s tax practice works alongside the immigration team to ensure that the legal and fiscal aspects of an applicant’s position are aligned from the outset.
Annual Compliance Obligations
Continued entitlement to TRP status is conditional on meeting the following obligations each year:
- Retention of the qualifying property (whether owned or rented)
- Maintenance of the comprehensive EU-wide health insurance policy
- The main applicant must not reside in any other jurisdiction for more than 183 days in any calendar year
- Filing of an annual declaration alongside the annual tax return
GVZH, as Authorised Registered Mandatory, manages the annual compliance obligations on behalf of its TRP clients, including the preparation and submission of the annual declaration and coordination with the International & Corporate Tax Unit.
Dependants
Family members may be included as dependants on the TRP certificate. The definition of dependant and the conditions applicable differ by relationship and circumstance. GVZH advises on the correct structuring of the application to ensure all intended family members are properly included from the outset, avoiding the need for subsequent amendments.
Frequently Asked Questions
What is the difference between the TRP and the GRP?
The TRP and GRP are structurally identical in terms of tax treatment and property requirements. The key distinction is nationality: the TRP is available to EU, EEA and Swiss nationals, while the GRP is available to third-country nationals. Maltese nationals are excluded from both programmes.
Can I work in Malta under the TRP?
The TRP is a residence and tax status programme -it does not in itself authorise employment in Malta. EU and EEA nationals have the right to work in Malta by virtue of free movement rules. Swiss nationals should seek specific advice on their employment rights. Income arising from Maltese employment will, however, be taxed at 35% rather than the special 15% rate.
Do I need to spend a minimum number of days in Malta under the TRP?
The TRP does not impose a minimum physical presence requirement in Malta. It does, however, require that the main applicant does not reside in any other single jurisdiction for more than 183 days in a calendar year. This is a distinct condition from a minimum Malta presence requirement.
What happens if I sell or change my qualifying property?
Any change to the qualifying property must be notified and a replacement qualifying property must be secured to maintain TRP status. GVZH advises on the correct procedure for property changes and coordinates with the International & Corporate Tax Unit accordingly.
Can previous HNWI status holders transition to the TRP?
Yes. Individuals who were granted special tax status under the predecessor High Net Worth Individuals Rules for EU/EEA/Swiss nationals may apply to the International & Corporate Tax Unit to be granted equivalent status under The Residence Programme Rules.
