Malta Global Residence Programme for Americans

Malta's Global Residence Programme (GRP) is a tax status, not a work permit. It gives people who own or rent qualifying property in Malta a flat 15% tax rate on foreign income they bring into Malta, subject to a minimum annual tax. For Americans with investment income, a business abroad or a pension, it has been one of Malta's main programmes. It is also about to change: a new Individual Tax Programme takes over from 1 January 2027. This guide sets out the GRP rules from its legal notice and the Malta Tax and Customs Administration (MTCA), the transition, and how US taxes fit.

What the GRP is

The GRP is set up by the Global Residence Programme Rules, Legal Notice 167 of 2013. The MTCA's special schemes page groups it with other programmes for people relocating to or retiring in Malta: the Residence Programme, the Malta Retirement Programme, the United Nations Pensions Programme and the High Net Worth Individuals Rules.

The MTCA describes the shared benefit: the right to pay tax at a flat 15% on foreign-source income remitted to Malta, with any other income, such as Maltese-source income, taxed at a flat 35%. Tax is subject to a minimum annual tax liability that covers the main applicant and the dependants on the same application.

Property requirement

Under the GRP rules, the applicant must hold a qualifying property in Malta, either owned or rented. The thresholds:

| | Malta (general) | Gozo or the south of Malta | |---|---|---| | Purchase | at least €275,000 | at least €220,000 | | Rent | at least €9,600 a year | at least €8,750 a year |

Rented property needs a lease, and in Malta every residential lease must be registered with the Housing Authority to be valid.

Minimum tax

The GRP's minimum annual tax is €15,000. If 15% of your remitted foreign income comes to less than that, you still pay €15,000. The minimum covers you and the dependants on your application.

### What "remitted" means

Malta taxes non-domiciled residents on foreign income only when it is received in Malta. The MTCA's tax residence page explains that this remittance basis applies to people who are resident but not domiciled in Malta. Under the GRP, foreign income you bring into Malta is taxed at 15%. Foreign income you leave abroad is not taxed in Malta, but the €15,000 minimum still applies.

What the GRP does not do

• It does not authorise work in Malta. If you want a Maltese job, you need a separate work permit.
• It does not cover Maltese-source income at 15%. Maltese income is taxed at 35% under the programme.
• It does not replace your residence permit. Identità still issues residence documents and biometrics.

Health insurance and residence formalities

Tax status and residence documents are separate steps. Identità, which issues residence cards to non-EU nationals, sets a health insurance rule for non-EU residents: private cover of at least €100,000. After approval of a residence application, you attend a biometrics appointment, where Identità issues an interim receipt, and later collect the card from its office in Msida.

### Days in Malta

The MTCA's tax residence page says a person is generally treated as resident if they spend more than 183 days in Malta in a year. Keep records of your days, lease and utility bills, since your status under any programme depends on being a Maltese tax resident in practice. Also check your US state's rules: some states keep taxing former residents who keep strong ties there.

The change on 1 January 2027: the Individual Tax Programme

Legal Notice 195 of 2026, the Individual Tax Programme Rules 2026, was published in the Government Gazette on 14 July 2026. It creates a new programme that takes over from 1 January 2027. The key changes:

• Minimum tax rises to €35,000 a year. Pensioners pay a minimum of €15,000 and UN pensioners €20,000.
• Property: at least €700,000 to buy, or €14,000 a year to rent.
• Status length: five years, renewable.
• Fees: €8,500 to apply and €2,500 to renew.

### Transitional rule

People who hold GRP status, or whose applications are submitted by 31 December 2026, keep the old rules until 31 December 2031. If you are deciding now, the date matters: a 2026 application keeps the €275,000 or €9,600 thresholds and the €15,000 minimum for five more years.

The retirement programme alternative

The Malta Retirement Programme is for people whose main income is a pension. It requires that the pension is at least 75% of your chargeable income and is received in Malta. Its minimum tax is €7,500 plus €500 per dependant, and the fee is €2,500. Retirees should compare the two; our retirement programme guide covers it.

The US side

### You still file a US return

The GRP changes your Maltese tax, not your US tax. US citizens file a US return on worldwide income.

### The US-Malta treaty

The US and Malta signed an income tax treaty that entered into force on 23 November 2010 and has applied since 1 January 2011. The IRS publishes the treaty and technical explanation. The treaty contains provisions on residence and on special tax regimes; read the documents or ask a cross-border adviser before relying on treaty benefits.

### Foreign tax credit

US citizens can usually claim a foreign tax credit for Maltese income tax paid on the same income. Because the GRP taxes remitted income at 15%, and the US taxes many types of income at higher rates, the credit often reduces but does not remove US tax.

### Foreign earned income exclusion

The FEIE ($130,000 for 2025 and $132,900 for 2026) applies only to earned income, meaning wages and self-employment income. It does not apply to investment income, pensions or Social Security. Many GRP applicants live mainly on investment income, so the FEIE does not help them.

### Reporting

• FBAR if your foreign accounts exceed $10,000 combined at any time in the year.
• Form 8938 for Americans abroad at $200,000 at year end or $300,000 at any time for single filers, double for joint.

Steps to apply

1. Decide before 31 December 2026 whether to apply under the GRP or wait for the new programme.
2. Buy or rent a qualifying property and register any lease.
3. Submit the application under the GRP rules and the MTCA's special schemes process.
4. Complete residence formalities with Identità.
5. File Maltese returns each year and pay at least the minimum tax.
6. Keep filing US returns, FBAR and Form 8938 as required.

Common questions

What tax rate applies under Malta's Global Residence Programme? Foreign-source income remitted to Malta is taxed at a flat 15%, and other income, such as Maltese-source income, at 35%, with a minimum annual tax of €15,000.

What property do I need for the GRP? A property bought for at least €275,000, or €220,000 in Gozo or the south, or rented for at least €9,600 a year, or €8,750 in Gozo or the south.

Is the GRP changing? Yes. Legal Notice 195 of 2026 creates the Individual Tax Programme from 1 January 2027, with a €35,000 minimum tax and higher property thresholds. GRP status holders and applications by 31 December 2026 keep the old rules until 31 December 2031.

Does the GRP reduce my US taxes? No. US citizens file on worldwide income. Maltese tax paid can usually be claimed as a foreign tax credit, and the US-Malta treaty applies.