The Global Residence Programme (‘GRP’) Rules were introduced by virtue of Legal Notice 167 of 2013 and came into force with effect from 1st July 2013. The GRP Rules are set to attract third-country nationals who wish to buy high-value property in Malta, whilst benefiting from a Malta residence permit (which has to be applied for with a separate application).
Individuals who qualify under the GRP Rules are taxable at the rate of 15% on foreign source income remitted to Malta with the possibility to claim double taxation relief.
- Why Choose Malta?
- The Global Residence Programme (GRP) Grants
- Tax Treatment in Malta under GRP
- GRP Eligibility Criteria
- Qualifying Property in Malta
- Household Staff
- GRP Fees
- Continuing Obligations
Why Choose Malta?
- Republic island in the central Mediterranean;
- Politically and Economically stable;
- 2nd safest country in the world (World Risk Report 2018);
- Economic growth higher than most EU countries;
- Commonwealth member state;
- Member of the EU since 2004; and
- Part of the Schengen Area since 2007.
The Global Residence Programme (GRP) Grants
- Special tax status in Malta;
- A Maltese residence permit to holders (via a separate application);
- Possibility to pass on the Special Tax Status to one’s heirs under certain terms; and
- The above benefits without the obligation for long-term residency in Malta.
Tax Treatment in Malta under GRP
- Beneficiaries taxable at the rate of 15% on foreign source income remitted to Malta;
- Foreign source capital gains not taxable even if remitted to Malta;
- Possibility to claim double taxation relief;
- Malta source income charged as separate income at the rate of 35%; and
- A minimum tax of € 15,000 is payable by the holder of the tax status in respect of any year of assessment.
GRP Eligibility Criteria
An Applicant Must:
- Be represented by an authorised registered mandatory (ARM);
- Be a third country national and a Non Maltese, EEA or Swiss national;
- Be in possession of health insurance for him/herself and his/her dependents;
- Have stable and regular resources;
- Pass a Fit and Proper test;
- Be in possession of a valid travel document;
- Be fluent in one of the official languages of Malta (English & Maltese); and
- Hold a qualifying property.
Qualifying Property in Malta
An aspiring applicant of the special tax status, who is not a long term resident, is required to hold a qualifying property, the holding being either:
- Immovable property in Malta for a value of not less than €275,000, or if the property is located in the south of Malta or in Gozo, the value shall not be less than €220,000; or
- Rented immovable property in Malta for not less than €9,600 annually, or if the property is located in the south of Malta or in Gozo, the value shall not be less than €8,750 annually.
Household staff can also be included in the application. The definition refers to an individual or individuals who has/have been providing services to the beneficiary in a systematic manner for at least two years prior to an application for special tax status in terms of the Global Residence Programme. A beneficiary may have more than one household staff at any time.
A non-refundable one-time registration fee of €6,000 (€5,500 in the case of applications involving a qualifying property holding in the south of Malta or in Gozo) must be paid upon application.
The GRP Rules list a set of continuing obligations that need to be satisfied by all successful applicants, being that the individual must:
- Not become a Maltese, EEA or Swiss national;
- Retain holding of the Qualifying Property;
- Not become a long-term resident;
- Retain insurance for himself/herself and his/her dependents and continue to have stable resources; and
- Must not stay in any other jurisdiction for more than 183 days in a calendar year. The GRP Rules also set up special reporting obligations, being the filing of an annual tax return and other notifications that must be complied with.