Taxation Magazine: Chetcuti Cauchi on Malta’s Stable Non-Dom Tax Regime for UK Non-Doms and HNW Families

This article was published in Taxation Magazine, 24 March 2025.

The  Origin and Evolution of the Res, Non-Dom tax system in Malta: The Res, Non-Dom tax rules of Malta are deeply intertwined with the British tax system, from which it originates. The introduction of Malta’s Income Tax Act in the 1940s under British colonial governance established the foundation for Malta's personal tax framework, which has since imposed taxation on non-domiciled resident individuals, known as Res, Non-Doms. This historical connection ensures that UK residents will find Malta's tax environment both familiar and beneficial advantageous option. Malta imposes tax on Res, Non-Doms only on Maltese-source income and foreign income that is remitted to Malta.  

Malta's journey to becoming a premier residency destination is rooted in its strategic efforts to create a competitive and favourable tax environment. Over the past few decades, Malta has systematically enhanced its legal and fiscal structures to appeal to international investors and expatriates. By aligning its policies with global best practices while retaining unique advantages, Malta has outpaced other jurisdictions that once held similar allure.

Malta's Res, Non-Dom tax system offers significant benefits. Non-domiciled residents are only taxed on Maltese-source income and foreign income that is remitted to Malta. In contrast to the UK Res, Non-Dom system, in Malta, unremitted foreign income and capital gains, whether remitted or not, are not subject to taxation, providing substantial tax relief for Maltese non-domiciled residents.

To qualify as a tax resident in Malta, an individual must either spend at least 183 days in Malta within a basis year or demonstrate an intention to reside in Malta. This intention can be evidenced by economic, personal, social, or other types of presence.

Malta's remittance basis regime applies a minimum annual tax of €5,000 on those claiming Maltese Res, Non-Dom tax status. This is significantly lower compared to the charges imposed by the UK, as well as the minimum lump sum taxes payable by Swiss and Italian residents, making the Mediterranean Island a front-runner ahead of many European jurisdictions.

Malta does not have a deemed domicile rule, allowing individuals to maintain their non-domiciled status indefinitely. Additionally, the Maltese tax system does not require individuals to be non-residents of Malta for any period before taking up tax residency. Malta does not impose inheritance or wealth tax.  Stability is a key feature of Malta's tax regime.

For the full article on Taxation.co.uk, subscription may be required: Malta: a former British colony offering stability for non-doms.

Magdalena Velkovska (Director, Private Client Tax) and Jean-Philippe Chetcuti (Managing Partner) advise internationally mobile individuals, families and private wealth advisers on Malta tax residence and resident non-dom planning, with an emphasis on evidence-led residence, compliant remittance patterns, and cross-border. Miles Dean is Partner and Head of International Tax at Andersen LLP and writes on international tax matters affecting globally mobile individuals and families.

[question]What does Malta’s resident non-dom tax basis generally tax?[/question]
[answer]As summarised in this publication page, Malta’s resident non-dom position taxes Maltese-source income and foreign income remitted to Malta, with the remittance basis mechanics explained in the article.[/answer]

[question]How is tax residence typically established in Malta?[/question]
[answer]This page outlines two routes discussed in the article: spending 183+ days in Malta within a basis year, or demonstrating an intention to reside supported by economic, personal and social indicators.[/answer]

[question]Where can I read the original Taxation Magazine article?[/question]
[answer]The original appears on Taxation.co.uk under the title “Malta: a former British colony offering stability for non-doms”. Subscription may be required.[/answer]