Highly Skilled Individuals (HSI) Rules – Malta Tax Framework

The Highly Skilled Individuals (HSI) Rules provide a structured tax framework in Malta designed to attract experienced professionals in key sectors such as financial services, remote gaming, aviation, healthcare, and other specialised industries.

The programme offers preferential tax treatment for employees working with licensed or recognised entities regulated by the Malta Financial Services Authority (MFSA), Malta Gaming Authority (MGA), Transport Malta, Malta Enterprise, or the Office of the Chief Medical Officer. Introduced under Legal Notice 20 of 2026, the HSI Rules replace the previous Highly Qualified Persons (HQP) Rules, creating a more transparent and substance-driven regime for high-income professionals relocating to Malta.

Highly Skilled Individuals (HSI) Rules Malta – Key Facts

• Programme type: Malta tax residence framework for highly skilled professionals
• Legal basis: Introduced under Legal Notice 20 of 2026 replacing the Highly Qualified Persons (HQP) Rules
• Eligible sectors: Financial services, fintech, remote gaming, aviation, healthcare & specialised industries
• Eligible employers: MFSA, MGA, Transport Malta, Malta Enterprise & Chief Medical Officer regulated or recognised entities
• Eligible roles: CEO, CFO, COO, CTO, CIO, CCO, senior analysts, R&D leaders & other executive positions
• Minimum salary requirement: €65,000 annual income excluding fringe benefits, increasing every five years
• Professional experience requirement: Minimum five years of relevant industry experience
• Tax benefits: 15% flat tax rate on qualifying employment income up to €7,000,000 annually
• Additional income taxation: Income exceeding €7,000,000 taxed at 35%
• Benefit duration: Five-year period renewable twice up to a maximum of 15 years
• Residency requirements: Maltese employment contract, non-domicile status & qualifying health insurance cover
• Compliance obligations: Malta tax return filings, income disclosure & ongoing substance requirements
• Application deadline: 31 December 2035
  Programme end date: No HSI tax benefits applicable after 31 December 2040
• HQP transition rules: Existing HQP beneficiaries may transition to HSI framework until 31 December 2028
• Business advantages: Supports talent attraction, executive relocation & long-term employment planning in Malta
• Additional support services: Residency planning, relocation assistance, tax compliance & employment documentation

Who Can Qualify?

Applicants may be eligible under the HSI Rules if they:

• Are employed by a licensed or recognised entity in Malta.
• Occupy an eligible senior position such as CEO, CFO, COO, CTO, CCO, CIO, Head of Research & Development, Senior Analyst, or equivalent roles.
• Earn a minimum annual income of €65,000 (exclusive of fringe benefits), adjusted upwards by €10,000 every five years.
• Have at least five years of relevant professional experience.
• Are non-domiciled in Malta at the time of application.
• Hold a valid Maltese employment contract and adequate health insurance covering themselves and their dependants.

Example roles include:

• Financial services: Investment managers, senior compliance officers, fintech directors.
• Remote gaming: Technical directors, iGaming operations managers, senior analysts.
• Aviation: Flight operations managers, continuing airworthiness managers.
• Healthcare & specialised sectors: Senior medical professionals, regulatory specialists, and R&D leaders.

Key Benefits

Eligible employees under the HSI Rules benefit from:

• A flat tax rate of 15% on qualifying employment income up to €7,000,000 per annum.
• Income exceeding €7,000,000 is taxed at 35%.
• A structured benefit period of five years, renewable twice for additional five-year periods, up to a maximum of 15 years.
• A clear and predictable tax framework designed to support long-term relocation and employment planning in Malta.

Compliance & Documentation Requirements

Applicants must demonstrate:

• Genuine and substantive professional activity in Malta.
• Employment aligned with HSI eligibility criteria.
• Full disclosure of all employment income and emoluments.
• Maintenance of appropriate residence and health insurance coverage in Malta.
• Ongoing compliance with Maltese tax obligations, including timely submission of tax returns.

Failure to meet these requirements may result in loss of eligibility or termination of benefits.

Programme Timeline

• Application deadline: 31 December 2035
• End of benefit period: No benefits apply to income earned after 31 December 2040

These timelines are key considerations for long-term tax and relocation planning.

Transitional Provisions for HQP Beneficiaries

• Individuals who were benefiting under the HQP Rules as at 31 December 2025 may continue under their existing approvals.
• Such individuals may also opt to transition into the HSI Rules, subject to meeting the relevant criteria.
• The deadline to transition into the HSI framework is 31 December 2028.

Practical Applications for Businesses and Professionals

The HSI Rules are widely used by senior professionals across:

• Financial services: Banks, investment firms, fintech companies.
• Remote gaming: Senior managers, directors, and technical leads.
• Aviation: Flight operations, airworthiness, and training management.
• Healthcare and specialised industries: Senior practitioners and technical experts.

The framework enables employers to attract and retain high-level talent while offering professionals a competitive and predictable tax environment.

CSB Group Support

CSB Group provides guidance on:

• Assessing eligibility under the HSI Rules.
• Preparing and submitting employment and tax documentation.
• Ensuring ongoing compliance with Maltese tax regulations.
• Advising on residency planning and relocation requirements for employees and their families.

Our team supports both individuals and organisations in navigating the HSI framework efficiently, ensuring a smooth application process and long-term compliance.