Our tax advisory team at CSB Group understands that Family Wealth and Estate Planning requires appropriate planning. We ensure that your wealth can be transferred in a tax efficient and legitimate way to the desired beneficiaries.
From a tax perspective, Malta presents one of the most favourable environments in Europe for family wealth and estate planning. Malta does not impose inheritance tax, estate duty, or wealth tax, meaning that the intergenerational transfer of assets , whether by gift during one's lifetime or upon death, does not give rise to a tax charge at the level of the recipient. Capital gains on the transfer of securities and most financial assets are similarly not subject to tax in Malta, making the jurisdiction particularly well-suited for holding investment portfolios and family wealth structures.
For non-domiciled individuals resident in Malta, the remittance basis of taxation means that foreign-source income is only taxable in Malta to the extent it is brought into the country, and foreign capital gains are entirely exempt from Maltese tax regardless of whether they are remitted. This framework allows high-net-worth families to retain significant flexibility over how and when wealth flows between jurisdictions, and to structure their affairs in a fully compliant and tax-efficient manner.
Malta has also developed a dedicated and increasingly sophisticated ecosystem for family office structures. The Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules, effective from 1 January 2025 and applicable from the year of assessment 2026, introduced a flat 15% income tax rate for qualifying senior employees within Malta-based single-family and multi-family offices, back-office support operations, and treasury management undertakings. Eligible roles include Chief Executive Officers, Chief Investment Officers, Portfolio Managers, Senior Traders, Senior Structuring Professionals, and Compliance and Risk Management Heads, with the 15% rate applying to qualifying employment income up to €7 million per annum. The benefit is granted for an initial period of five years, extendable up to a maximum of 15 years where conditions continue to be met, with the regime expiring on 31 December 2040. Note that this regime has since been consolidated into the broader Highly Skilled Individuals Rules introduced by Legal Notice 20 of 2026, which harmonises the tax treatment of qualifying expatriates across multiple sectors including family offices.
Malta's legislative framework also caters for a range of wealth-holding vehicles suited to family office structures, including notified private investment funds that may be managed by an in-house investment manager exempt from MFSA licensing where the fund is established with a minimum investment of €5 million, as well as trusts, foundations, companies, and sub-fund structures targeting specific asset classes.
CSB Group, through its licensed fiduciary and trustee subsidiary CSB Fiduciaries and Trustees Limited, is well positioned to assist families and their advisors in designing and implementing holistic wealth and succession structures that are both tax efficient and aligned with long-term family objectives.
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