1. What Is the HQP Scheme?
- The HQP Rules are designed to attract senior, highly qualified professionals to Malta.
- It applies to “eligible offices” within sectors like financial services, online gaming, aviation, and (since a 2018 amendment) medical / assisted-reproduction roles.
- The legal basis for the scheme is Legal Notice 106 of 2011, as amended.
2. Who Is Eligible / Who Should Apply
To benefit from the HQP Rules, individuals must satisfy all (or most) of the following:
- Be employed under a qualifying contract of employment in Malta.
- The employer must be licensed / recognised by a competent authority, depending on the sector:
- Financial services — MFSA-licensed.
- Gaming — MGA-licensed.
- Aviation — Air Operator or Aerodrome Licence via Transport Malta.
- Medical / Assisted Reproduction — certain roles like embryologists, quality managers.
- The applicant must hold professional qualifications and have at least 5 years of experience.
- Minimum income from that contract: €75,000, indexed over time.
- The individual must not be domiciled in Malta.
- Must have health insurance covering self and dependents, and stable resources to support family without public assistance.
- Must reside in accommodation in Malta that meets ordinary health & safety standards.
- Valid travel document required.
3. Tax Treatment & Benefits
- Flat tax rate of 15% on employment income from the qualifying contract.
- The 15% rate applies on income up to €5,000,000.
- Any income from that contract exceeding €5 million is exempt from Maltese tax.
- The duration of this tax benefit:
- EEA / Swiss nationals: 5 years, with the possibility of two extensions.
- Third-country nationals: 4 years, also may extend (per rules) to a maximum.
- Anti-abuse rule: “split contracts” (payments from related parties not declared) are treated as artificial arrangements.
- If a non-EEA beneficiary acquires “real rights” over property in Malta (or similar interest), HQP benefits may be withdrawn with retrospective effect.
- Penalty for misuse: claiming the benefit when not entitled may lead to repayment + extra tax.
4. Duration & Recent Regulatory Updates
- Under Legal Notice 29 of 2021, the scheme’s expiry was extended: no new determinations can be issued after 31 December 2025, but benefits may apply for eligible employment that commences by 31 December 2026 and can apply up to 31 December 2030.
- Also under LN 29/2021: beneficiaries can now apply for two renewals/extensions:
- EEA / Swiss nationals: two further 5-year extensions (up to 15 years total)
- Third-country nationals: two further 4-year extensions (up to 12 years)
- Previous restriction for third-country nationals (physical stay > 1,460 days) was removed.
5. Why It’s Attractive / Why Use HQP
- Very favorable tax rate (15%) compared to Maltese standard income tax.
- For very high earners (income > €5 million) the excess is not taxed, providing a huge benefit.
- Targets senior-level roles — CEO, CFO, CTO, Portfolio Manager, senior traders, analysts, etc.
- It helps multinational companies in financial, gaming, aviation, and medical sectors attract global talent to Malta.
- Extension flexibility: up to 15 years in total for EEA / Swiss nationals under the current rules.
- Safe, EU-regulated jurisdiction with Malta’s strong business infrastructure. (implied through scheme structure)
Disclaimer: We are not licensed or authorised to provide legal, tax, or financial advice regarding Maltese residency or investment schemes. Any information provided is for general guidance only and should not be relied upon as professional advice. Please consult a licensed advisor for personalised assistance.
