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Overview of Malta’s Highly Skilled Individuals Framework
The Highly Skilled Individuals framework introduced in Malta in 2026 provides a specific tax treatment for qualifying employment income, subject to a detailed set of legislative and regulatory conditions.
At A2CO, we support employers and senior individuals in assessing whether this framework may apply in practice. Our approach focuses on understanding how tax, employment structure, regulatory recognition, and substance in Malta interact, rather than relying on assumptions driven by headlines or isolated criteria.
This page is intended to explain the framework at a high level and outline how we support eligibility assessment. It should be read alongside professional tax, regulatory, and employment advice.
Highly Skilled Individuals Rules Malta: Framework, Scope and Advisory Support
What changed in Malta’s Tax Framework in 2026
In 2026, Malta introduced Legal Notice 20 of 2026, which consolidated and replaced several earlier regimes that had applied to highly qualified or highly skilled individuals. The intention was to modernise and streamline the framework in response to changes across regulated industries and increased scrutiny on substance, governance, and regulatory alignment.
The rules apply from 1 January 2026 and form part of the wider Income Tax Act framework. Importantly, the legislation does not operate in isolation. It interacts with employment law, immigration requirements, sector specific regulation, and corporate governance obligations.
While certain concepts may appear familiar to individuals who previously fell under earlier regimes, the 2026 framework should not be treated as a direct continuation. Eligibility must be reassessed under the new rules and cannot be assumed to carry over automatically. Where interpretation remains subject to administrative practice or future guidance, a cautious and case specific assessment is required.
Who the Framework is Designed For
The 2026 framework is intended to apply in situations where Malta based businesses require senior expertise in roles that are strategic, specialised, or subject to regulatory oversight. This includes both employers seeking to fill such positions and individuals who occupy them.
Typical contexts may include financial services, iGaming, crypto and regulated technology, as well as aviation and maritime activities. In these sectors, certain functions are closely monitored by competent authorities, and individuals may be expected to demonstrate competence, experience, and ongoing accountability.
The framework reflects this reality by linking tax treatment to the function actually performed, rather than to job titles, income level alone, or generic classifications of skill.
How A2CO Supports Eligibility Assessment
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Treats the Highly Skilled Individuals framework as a coordination exercise rather than a standalone tax issue
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Reviews tax, employment, regulatory, and corporate considerations together in a structured assessment
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Examines how roles are defined and exercised in practice, not only how they are described on paper
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Identifies where regulatory recognition or authority engagement may be required
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Checks alignment between employment contracts, governance arrangements, and underlying facts
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Helps identify misplaced assumptions, gaps, or inconsistencies before reliance is placed on the framework
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Supports both employers and individuals seeking clarity on how the 2026 rules may apply to their circumstances
What changed in Malta’s Tax Framework in 2026
In 2026, Malta introduced Legal Notice 20 of 2026, which consolidated and replaced several earlier regimes that had applied to highly qualified or highly skilled individuals. The intention was to modernise and streamline the framework in response to changes across regulated industries and increased scrutiny on substance, governance, and regulatory alignment.
The rules apply from 1 January 2026 and form part of the wider Income Tax Act framework. Importantly, the legislation does not operate in isolation. It interacts with employment law, immigration requirements, sector specific regulation, and corporate governance obligations.
While certain concepts may appear familiar to individuals who previously fell under earlier regimes, the 2026 framework should not be treated as a direct continuation. Eligibility must be reassessed under the new rules and cannot be assumed to carry over automatically. Where interpretation remains subject to administrative practice or future guidance, a cautious and case specific assessment is required.
Who the Framework is Designed For
The 2026 framework is intended to apply in situations where Malta based businesses require senior expertise in roles that are strategic, specialised, or subject to regulatory oversight. This includes both employers seeking to fill such positions and individuals who occupy them.
Typical contexts may include financial services, iGaming, crypto and regulated technology, as well as aviation and maritime activities. In these sectors, certain functions are closely monitored by competent authorities, and individuals may be expected to demonstrate competence, experience, and ongoing accountability.
The framework reflects this reality by linking tax treatment to the function actually performed, rather than to job titles, income level alone, or generic classifications of skill.
How A2CO Supports Eligibility Assessment
-
Treats the Highly Skilled Individuals framework as a coordination exercise rather than a standalone tax issue
-
Reviews tax, employment, regulatory, and corporate considerations together in a structured assessment
-
Examines how roles are defined and exercised in practice, not only how they are described on paper
-
Identifies where regulatory recognition or authority engagement may be required
-
Checks alignment between employment contracts, governance arrangements, and underlying facts
-
Helps identify misplaced assumptions, gaps, or inconsistencies before reliance is placed on the framework
-
Supports both employers and individuals seeking clarity on how the 2026 rules may apply to their circumstances
Why A2CO
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Coordinated eligibility assessment: We assess tax, employment, regulatory, and immigration considerations together rather than in isolation.
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Experience with regulated senior roles: We regularly work with roles subject to recognition by authorities such as the MFSA, MGA, Transport Malta, Malta Enterprise, and the Office of the Chief Medical Officer.
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Focus on substance over form: We review how roles operate in practice and how responsibilities are documented, not just how they are described.
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Early risk identification: We help identify potential gaps or inconsistencies before reliance is placed on the framework.
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Advisory support without guarantees: We provide structured advisory support without promising acceptance or tax outcomes.
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Support for employers and individuals: We assist both organisations structuring senior roles and individuals assessing whether the framework may be relevant to their circumstances.
Frequently Asked Questions
No. The tax rate is an outcome of the framework and applies only where all legislative conditions are met and the framework is accepted by the competent authorities. Meeting an income level alone is not sufficient.
No. Transitional arrangements are not automatic. Individuals must meet the applicable conditions under the new framework and obtain approval from the relevant competent authority.
No. Eligibility depends on the role and functions actually performed, how the role is exercised in Malta, and whether it is recognised where required. Job titles alone are not determinative.
A2CO does not provide confirmations or guarantees. Our role is to support a structured assessment of eligibility and alignment across tax, employment, regulatory, and immigration considerations before reliance is placed on the framework.
The framework requires genuine employment activity and substance in Malta. Where a role is effectively exercised outside Malta, eligibility may be challenged depending on the facts and regulatory expectations.
Let’s discuss the Highly Skilled Individuals Rules in Malta
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