TAXATION OF NEW CITIZENS
In itself, becoming a citizen of Malta under the IIP does not require one to transfer his/her taxability to Malta. However, should the applicant consider this to be advantageous, one may carry out such a transfer.
It is necessary to consider both domicile and residence to establish the exact tax situation of individuals in Malta (not citizenship). The grant of Maltese citizenship to a non-domiciliary of Malta does not cause the beneficiary to acquire a new domicile of choice in Malta. Residence for tax purpose on the other hand is established by demonstrating an intention to reside in Malta for a period of more than 183 days in a calendar year.
A non-resident, non-domiciled citizen of Malta would be taxable in Malta as follows:
- Income arising outside Malta which is received in Malta would be chargeable to tax in Malta at progressive rates, the maximum being 35%;
- Income arising in Malta and capital gains realized in Malta would be taxable in Malta at 35%;
- No Malta tax would be chargeable on income arising outside Malta which is not received in Malta; and
- No Malta tax would be chargeable on capital gains realized outside Malta even if these are received in Malta
Individuals also have the possibility of claiming double tax relief. Such relief would be available under a treaty in force between Malta and the country of source of the relevant income or, alternatively, by way of unilateral relief – available in terms of domestic tax legislation. Treaty or unilateral relief would generally be available in the form of an ordinary credit against the beneficiary’s Malta income tax liability.