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posted 3 hours ago
On 16 January 2026, the Malta Tax & Customs Administration (MTCA) issued official Guidelines in relation to the Nomad Residence Permits (Income Tax) Rules (S.L. 123.210).
While the Nomad Residence Permit (MNRP) framework remains broadly the same from an immigration perspective, the publication is an important development because it clarifies the tax treatment of Nomad Permit holders and confirms how Malta’s tax system applies to “authorised work” performed remotely.
Below is a summary of the key new clarifications introduced in the MTCA Guidelines.
1) 10% flat tax rate on “authorised work” (formal confirmation)
The Guidelines confirm that eligible Nomad Residence Permit holders may benefit from a flat tax rate of 10% on income derived from authorised work (as defined in the Rules), instead of Malta’s standard progressive income tax rates (which may go up to 35%).
This is particularly relevant for remote employees and freelancers who wish to have certainty on how their work income will be treated for Malta income tax purposes.
2) 12-month income tax exemption confirmed (starting point clarified)
One of the most practical clarifications is that Nomad Permit holders may benefit from a 12-month income tax exemption on income from authorised work.
Importantly, the Guidelines state that the 12-month period runs from the later of:
This provides clearer timing and removes ambiguity around when the exemption begins for individuals whose permit is issued after the tax framework became effective.
3) Automatic income tax registration in Malta (new operational point)
The MTCA Guidelines confirm that once a Nomad Residence Permit is issued, the holder will be automatically registered for income tax purposes in Malta.
This is a material practical update: applicants should be aware that tax registration is not merely optional or theoretical – it is an automatic step triggered by the permit issuance.
4) Compliance obligations: tax returns, payments & reporting changes
The Guidelines also underline that Nomad Permit holders must remain compliant with Maltese tax rules, including:
This is a key message for applicants who assume the programme is purely a residency arrangement without ongoing reporting responsibilities.
5) Confirmation that Nomad Permit holders remain outside the FSS (payroll relief)
The MTCA also clarified that Nomad Residence Permit holders should remain outside the scope of the Final Settlement System (FSS).
In practical terms, this means that foreign employers should generally have no Maltese payroll obligations, provided that the employer remains non-resident for tax purposes in Malta (and the employment arrangement remains aligned with the Nomad Permit framework).
This is a helpful clarification for international employers worried that their remote employee’s relocation could trigger payroll or registration exposure in Malta.
6) Who qualifies under the tax rules (scope restated)
The Guidelines restate that the Rules apply to non-EU/EEA/Swiss nationals holding a Nomad Residence Permit and who fall under one of these categories:
This reinforces the programme’s core condition: the income must arise from remote work outside the Maltese market.
Optional election to be taxed immediately
The MTCA Guidelines also introduce a practical mechanism allowing eligible Nomad Permit holders to elect to be taxed immediately (rather than benefiting from the initial 12-month exemption), through a written declaration submitted within the deadlines set out by the Guidelines.
This may be relevant where an applicant requires tax confirmation in Malta for reporting purposes.
Foreign tax relief and supporting evidence
Where foreign tax is paid on authorised work income, the Guidelines confirm that relief may be available in Malta, subject to submission of a Malta tax return, together with supporting documentation demonstrating the foreign tax suffered (as specified in the Guidelines).
Final note
The 2026 MTCA Guidelines represent an important step in providing tax certainty for Nomad Residence Permit holders and their employers. The immigration process remains familiar, but the publication makes it clear that tax registration and compliance will follow permit issuance, with defined treatment for authorised work income and a clarified exemption window.
For applicants seeking to relocate to Malta under the Nomad Residence Permit scheme, it is recommended to consider both:
Vaia Legal can assist with eligibility assessments, application support, and ongoing guidance on the relevant tax and compliance considerations throughout the duration of the permit. Contact us at info@vaialegal.com.
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