Malta Special Tax Residency for Senior Family Office Executives

• Senior family office executives relocating or employed in Malta.
• UHNW and multi-family offices establishing European operational centres.
• International wealth managers, fiduciaries and investment professionals providing advisory services from Malta.

What This Means for Family Offices in Malta

The new special tax residency regime enhances Malta’s competitiveness as a family office jurisdiction by reducing the tax burden on executive remuneration, encouraging the relocation of top-tier professionals and fostering the establishment of substance-rich, multi-generational family offices in Malta.

The Family Office (Special Tax Regime) Rules, 2025 were introduced by the Minister for Finance under powers conferred by Article 56(21) of the Income Tax Act (Cap. 123, Laws of Malta).

That provision empowers the Minister to prescribe a final tax rate applicable to income derived from an employment of a specialised nature carried out in Malta by persons possessing professional qualifications or senior management experience.
Pursuant to this authority, the 2025 Rules designate employment in family offices as a qualifying activity for the purposes of this article.

The measure forms part of Malta's 2025 fiscal programme to attract high-value talent in private wealth management, philanthropy advisory, and family governance, complementing existing frameworks such as the Highly Qualified Persons Rules (L.N. 106 of 2011) and the Highly Skilled Expatriates Rules (L.N. 104 of 2020).

To qualify under the 2025 Rules, an applicant must satisfy the following statutory conditions:

1. Employment: The applicant must hold a senior or specialised role within a family office licensed under the Family Office Services Act, 2024.
2. Minimum Remuneration: Annual basic remuneration must exceed €150,000, exclusive of fringe benefits.
3. Tax Residency: The income must arise from employment physically carried out in Malta and the individual must be ordinarily resident or tax resident in Malta during the year of assessment.
4. Administrative Approval: The Commissioner for Revenue must issue a determination of eligibility, valid for five years and renewable.
5. Compliance: The applicant must satisfy reporting obligations under Article 96 of the Income Tax Act and the recordkeeping obligations under Regulation 8 of the 2025 Rules.

Revocation may occur where false information is provided, the employment ceases to qualify, or the executive no longer fulfils residence or remuneration requirements.

The Income Tax (Amendment) Act, 2025 expanded the scope of Article 56(21) of Cap. 123 to include family office activities as “specialised employment.”
The Government Notice of 3 October 2025 confirms the purpose of the measure:

To enhance Malta's ability to attract senior family office professionals whose expertise contributes to the growth of the private capital and philanthropy sectors in Malta.

This measure operationalises Malta's Vision 2050, which emphasises the integration of family governance, sustainability and impact investment within the island’s financial ecosystem.

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Income derived under the regime:

• is subject to a final 15% flat tax;
• is excluded from global aggregation for Maltese tax computation purposes; and
• is not subject to further tax in Malta.

Ancillary income (e.g. non-employment income or board fees) remains taxable under ordinary rates.
Employers must maintain records evidencing eligibility, including proof of the family office’s registration and the employee’s senior management status.

The 2025 family office regime operates independently of other specialist employment schemes.
An executive benefitting under this regime cannot simultaneously claim relief under:

• the Highly Qualified Persons Rules (L.N. 106 of 2011),
• the Qualifying Employment in Innovation and Creativity Rules (L.N. 106 of 2020), or
• the Global Residence Programme (L.N. 167 of 2013).

This single-regime principle ensures fiscal transparency and compliance with Malta’s OECD BEPS Action 5 commitments on preferential regimes.

Malta’s legislative architecture now integrates three key components supporting family offices:

1. Family Office Services Act, 2024 – regulates family office establishment, licensing and governance.
2. Family Office (Special Tax Regime) Rules, 2025 – provides the fiscal framework for senior staff.
3. Philanthropy and Impact Governance Standards, 2025 – codifies ethical and reporting standards for private capital and philanthropic initiatives.

Together, these reforms position Malta as a compliant yet competitive European base for family offices seeking substance, governance quality and intergenerational continuity.

Our Family Office & Private Client Tax lawyers advise on:

• Establishing and licensing family offices under the Family Office Services Act, 2024;
• Preparing and submitting applications for Family Office employees under the Special Tax Regime;
• Structuring executive compensation frameworks in compliance with Cap. 123 and the 2025 Rules;
• Managing cross-border tax reporting, relocation and governance arrangements.

Our multidisciplinary approach brings together lawyers, accountants and tax advisors experienced in family governance, impact investment and succession planning.

About the Authors

Magdalena Velkovska, Director, Private Client Tax, advises internationally mobile individuals, senior executives and family offices on Maltese tax residence, resident non-domicile status, special tax regimes and cross-border private client planning. She leads the firm’s personal tax advisory and compliance work and coordinates mandates spanning tax, immigration and wealth structuring. Her experience is particularly relevant to the application of Malta’s special tax frameworks to senior and specialised roles, including family office executives relocating to or working from Malta.

Dr Priscilla Mifsud-Parker, Senior Partner – Tax, Family Office and Immigration, is a private client lawyer specialising in family office structuring, governance, trusts, estate planning and the preservation of family wealth across generations. She heads the Families & Wealth and Corporate, Trusts & Fintech practice groups and advises HNW families on the establishment and ongoing operation of regulated structures in Malta. A former Chairperson of STEP Malta and current member of its technical sub-committee, she brings a governance and structuring perspective to the regime’s practical use by family offices.

Our family office lawyers and tax advisors advise ultra-high-net-worth families, single and multi-family offices, and private capital advisers on Malta’s tax, residence, and family governance frameworks. The team contributes to STEP, TQR, and Wolters Kluwer publications on international family office structuring and regulation.