New Preferential Tax Regime For Senior Employees In Family Offices And Treasury Operations – Tax Authorities

CG

CSB Group

More

Established in 1987, CSB Group offers diverse yet specialised business solutions and commercial services to a vast portfolio of corporate and private clients seeking to setup a business or relocate to Malta. With an 100+ team of qualified professionals we strive to be a partner of choice to our clients, providing them with tailor-made solutions, uniquely aimed at helping them succeed.

By virtue of Legal Notice 250 of 2025, published on 17 October 2025, the Minister responsible for finance has introduced the Senior Employees of Family Offices…

Malta
Tax

Article Insights

By virtue of Legal Notice 250 of 2025,
published on 17 October 2025, the Minister
responsible for finance has introduced the Senior
Employees of Family Offices, Back Offices and Treasury Management
Operations Tax Rules,
2025 (the “Rules”). These Rules
establish a targeted preferential tax regime applicable to
qualifying senior employees engaged in eligible positions within
Single Family Offices, Multi Family Offices, Back Office functions
and Treasury Management Operations in Malta.

Through these Rules, Malta aims to attract experienced
professionals in the financial services sector and ensure the
system remains protected through strong anti-abuse measure.

Scope and Eligibility

The Rules  apply to individuals
earning income from a qualifying contract of
employment in an eligible senior
position, such as CEO, Managing Director, Head of Risk,
Head of Compliance, Portfolio Manager, Senior Trader, or other
roles listed in the Schedule.

The preferential 15% tax rate applies
to income earned as from basis year 2025 (YA
2026), provided the following conditions are met:

• Earn at least €65,000
  annually (indexed every five years).




• Hold relevant qualifications or professional
  experience.




• Have adequate
  accommodation and private health
  insurance in Malta.




• Not have previously benefited from another special tax
  regime.




• Be taking up their first employment in Malta in an
  eligible office after 1 January 2025.




• Be protected as an employee and
  perform genuine work.




• Fully disclose employment and related
  income for tax purposes.




• Demonstrate stable financial
  resources and suitable living arrangements.




• Comply with any additional
  conditions imposed by the competent authority.

Application Process

Applications may be submitted between the
publication of the Rules  and 31
December 2034, with the final acceptance deadline set
at 31 December 2035.

Eligibility is determined by the Malta Financial
Services Authority within 90 days of submission. Once
eligibility is confirmed, the individual may elect to be taxed at a
flat rate of 15% in terms of Article
56(21) of the Income Tax Act.

Tax Benefits

A flat tax rate of 15% applies to income derived from qualifying
employment, up to a maximum of €7 million per
annum. No deductions, reliefs or refunds are available,
other than credits under Article 23 of the Income Tax Management
Act.

The benefit is granted for an initial period
of five years, extendable up to a maximum
of 15 years if conditions continue to be
met. The regime expires on 31 December
2040.

Anti-Abuse Measures

The Rules contain strict anti-abuse provisions. The Commissioner
for Tax and Customs may:

• Request documentation to verify compliance;




• Deny or withdraw the benefit in cases of non-compliance or
  artificial arrangements; and




• Reassess tax under the ordinary rules where misuse is
  identified.

Applicants have recourse to the appeal procedures under
the Income Tax Management Act.

Key Takeaways

The introduction of this special tax regime underlines
Malta’s continued efforts to attract senior
financial professionals to support the development of
its family office and financial services
ecosystem, while ensuring that robust safeguards are in
place to prevent abuse.The 15% flat tax
regime, coupled with clear eligibility and compliance
requirements, provides a structured and predictable framework for
both individuals and family office operators considering Malta as a
strategic location.

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.