Category: Residency

What is the Malta Permanent Residence Programme (MPRP)?

The Malta Permanent Residence Programme (MPRP) was introduced in 2021, when it replaced the Malta Residence and Visa Programme (MRVP). The MPRP is designed to grant permanent residency to non-EU/EEA/Swiss nationals and their eligible family members. The programme aims to attract foreign investment while offering successful applicants the right to reside in Malta and access benefits such as visa-free travel within the Schengen Area.

The programme underwent some amendments by means of Legal Notice 310 of 2024 (published by the Maltese Government on 19 November 2024) and Legal Notice 146 of 2025 (published on 22 July 2025).

More Flexibility for the Applicants

Legal notice 146 of 2025 introduces two significant changes which result in more benefits for the applicants:

1. One-Year Temporary Residence Permit

Applicants can now obtain a temporary residence permit, valid for one year, after passing initial background checks. This would allow applicants to settle in Malta while the application is still ongoing. Should the application be rejected, the applicant and all individuals included in the application will see their permits revoked within 15 days.

• Property usage – possibility to let and sub-let the property in Malta

Applicants who own a property will be able to rent it out while they are not in Malta. For applicants who decide to rent a property, after 5 years they will be entitled to sub-let it (with the consent of their landlord) for the periods in which they are not in Malta.

Key Changes in Eligibility and Fees – The New Structure

The most significant changes are as follows:

• Financial Eligibility Criteria

These changes became effective in January 2025. Under new provisions, applicants will have two options:

1. showing that they have capital assets of a minimum €500,000, out of which a minimum of €150,000 must be financial assets; OR
2. show they have capital assets of a minimum €650,000, of which €75,000 must be in the form of financial assets.

• Age Limit for Dependant Children and New Fees for Dependants

Before the changes in the rules, a dependant child included in the application could be over 18 years old, unmarried, and primarily financially reliant on the main applicant. This applied to biological and adopted children of the main applicant or their spouse, provided they met the criteria set by the Residency Malta Agency. From 1 January 2025, the definition of a dependant child will change to include only those who are under 29 years old at the time of application. This new age limit does not apply to adult children certified by a recognised medical authority as having a disability.

• Qualifying Property Costs

Under the new regulations, the location of the property will not impact the financial contributions due by the applicant, which are set to €375,000 in case of property purchase, and to €14,000 in case the applicant decides to rent a property.

• Main Applicant’s Financial Contribution

The contribution that applicants will have to pay is now set to €37,000, regardless of whether the applicant purchases or rents a property.

• Administrative Fee

The administration fee amounts to €60,000. This fee is non-refundable, with €15,000 payable within one month of application submission and the remaining €45,000 due within two months of receiving the letter of approval in principle. An additional fee of €7,500 will apply for each dependant (adult children, parents and grandparents). No additional fee will be charged for the spouse or for minor children of the applicant.

• Donation to NGO

Applicants will also have to make a donation of €2,000 to a local philanthropic, cultural, scientific, artistic, sport or animal welfare NGO registered with the Commissioner of Voluntary Organisations.

Final Thoughts

Through recent amendments, the Malta Permanent Residence Programme reinforces its positioning as one of the most attractive programmes that allow free movement in the Schengen area. The new fee structure is less complex, and much easier to understand. Additionally, the temporary one-year permit and the possibility to rent or sub-let the property are significant benefits that were not included in previous versions of the programme.

How Dixcart Can Assist?

The Dixcart office in Malta has extensive experience in guiding clients through the application process of the MPRP and the various residence programmes available in Malta.

For further information, please contact Jonathan Vassallo at the Dixcart office in Malta: advice.malta@dixcart.com. Alternatively, feel free to reach out to your usual Dixcart contact.

With the Legal Notice No 159 of 2025, Malta has updated the regulations for the acquisition of Maltese citizenship. This framework replaces the previous citizenship programme known as “Citizenship by naturalisation for exceptional services” and creates a naturalisation model which is now centred on merit and public interest.

The revamped programme is aimed at individuals who render an exceptional service or make an exceptional contribution to the Republic of Malta or to humanity. Eligible individuals may include innovators and scientists, high-profile cultural figures, philanthropists, entrepreneurs, as well as distinguished figures in various sectors such as diplomacy, health, resilience, technology and sports, among others.

The Application Process

The application process is initiated with a letter that the individual interested in applying for Maltese citizenship must send to Community Malta Agency (Aġenzija Komunità Malta), the entity that will coordinate the entire process. The letter should include a comprehensive proposal to the Evaluation Board, with a detailed description of the exceptional achievement(s), contribution(s) or public service that the applicant intends to render in the national interest of Malta.

The Agency, once satisfied with the content of the letter, will conduct a first round of due diligence on the applicant and any dependant included in the application. Following the due diligence, the Evaluation Board will assess the application and issue a recommendation. This recommendation will be submitted to the Minister, who will either reject the application, or issue an “approval in principle”.

Following approval, the applicant will have to file an application for naturalisation on the basis of merit. This application should include:

• Proof of residence in Malta for a period of at least 8 months preceding the application date;
• Proof of title to adequate residential property in Malta;
• An indication of the exceptional service made or to be made;
• A confirmation of adequate knowledge of one of the official languages of the Republic of Malta;
• Proof of ties created with the Republic of Malta.

After the submission of the application, the Agency will update its due diligence and request the Board to issue another recommendation. The Agency will submit the recommendation to the Minister who has the power to accept or decline the application. For successful applications, the Agency will issue a Letter of Approval in favour of the applicant and his/her dependants (if any).

Within six months from the date of the Letter of Approval, applicants will have to confirm in writing their intention to continue to observe and fulfil the commitments that were mentioned in the application and take the oath of allegiance.

Guidelines and Fees

The Agency has the prerogative to issue guidelines on the procedures to be followed and to set administrative fees for the various stages of the process. It is also responsible of ensuring the ongoing fulfilment of commitment and obligation of the applicant.

Deprivation of Citizenship

The Minister shall have the power to deprive a person of the Maltese citizenship granted under this procedure, should the individual fail to comply with obligations and commitments mentioned in the Letter of Approval and in other particular cases.

Additional Information

Dixcart has extensive experience in handling citizenship and residency applications. Our Team is ready to assist applicants and deal with the relevant authorities throughout the entire process.

For further information about the acquisition of citizenship or for any other relocation programme available in Malta, please contact Jonathan Vassallo: advice.malta@dixcart.com. Alternatively, please speak to your usual Dixcart contact.

Portugal, with its golden beaches, vibrant culture, and attractive climate, has long been a magnet for expats seeking a dream holiday home or a lucrative short-term rental investment. While the allure is undeniable, managing the intricacies of property ownership and rental regulations as a non-resident requires a thorough understanding of the local landscape.

This article summarises essential aspects of owning a holiday home – whether it is only for personal use or for short-term rental.

The Appeal of Portuguese Property

Foreigners enjoy the same rights as Portuguese citizens when buying and owning property in Portugal, with no legal restrictions based on nationality. 

Reach out to Dixcart Portugal for more information (advice.portugal@dixcart.com).

Note this is not tax advice.

Portugal’s Golden Visa programme has adapted to meet evolving economic priorities, with a significant shift away from direct real estate investment. Today, one of the most prominent and popular pathways to Portuguese residency is through the investment in qualified funds. This route offers a professionally managed, diversified approach to investment while providing a clear path to European residency and potential citizenship.

The Rise of Fund Investments in the Golden Visa Landscape

Following legislative changes, particularly in late 2023, direct real estate purchases and real estate-related funds no longer qualify for the Golden Visa. This redirection has significantly boosted the appeal of investment funds, making them a preferred option for many applicants. These funds are designed to channel capital into productive sectors of the Portuguese economy, aligning with the country’s goals for growth and innovation.

The investment fund route has emerged as a practical and attractive option for individuals seeking Portuguese residency through the Golden Visa programme. By offering professional management, diversification, and a clear path to European benefits, it presents a compelling alternative for those looking to invest in Portugal’s dynamic economy. However, as with any significant financial decision, thorough research and expert guidance is always recommended.

Please contact Dixcart Portugal for more information: advice.portugal@dixcart.com.

Note that the article above is subject to change considering the immigration and nationality laws are under review. Please consult for the most up to date information.

Introduction

Major reforms regarding how new UK tax residents are taxed were introduced in April 2025. The changes have an impact on individuals who have been a tax resident in the UK for 4 years or more.

The Change from the Remittance Basis to the Foreign Income and Gains (FIG) Regime.

The remittance basis of taxation for non-UK domiciled individuals ceased on 5 April 2025 and was replaced with the new Foreign Income and Gains (FIG) regime. While initially more generous due to the initial UK tax exemption on foreign income and gains, the FIG regime is limited to a maximum of 4 years. After this period, individuals become fully taxable in the UK on their worldwide income and gains as they arise. In contrast, the remittance basis provided a tax advantage for up to 15 years. 

UK Tax Residence and the Possibility of “Resetting” the Clock

The FIG regime is based on an individual’s UK  tax residence. Individuals who are likely to be affected by the new rules should review their tax residence position and consider spending less time in the UK in order to cease being UK tax resident. This may allow them to avoid becoming subject to UK taxation on worldwide income or gains, if they wish to do so.

Through appropriate planning, ceasing to be UK tax resident for 10 years can result in the loss of FIG regime status. If individuals then choose  to return to the UK and become tax resident again, the FIG year count will reset.

Additional detail regarding the factors affecting UK resident and non-resident status can be found in the following Dixcart Article: The UK Resident/Non-Resident Test.

Tax Planning Opportunities

Individuals Seeking to Lose their UK Tax Residence

A Planning Example

Mr and Mrs Taxpayer spend between 125 and 140 days per year in the UK and have done so for the past  years (all of which they have been UK tax resident). While they are in the UK, they stay in an apartment they own in London. For the remainder of the year, they primarily live in Spain.

Mrs Taxpayer is a consultant and, while in the UK, spends the equivalent of 1 day per week (i.e. 52 working days per year) providing consultancy services to UK based clients.

UK tax residency considerations will take into account the following factors:

• Mr and Mrs Taxpayer currently spend more than 120 days in the UK per year;
• Each spouse is UK tax resident;
• They have both spent more than 90 days in the UK in the previous 2 tax years;
• They have an apartment available to them while they are in the UK; and
• Mrs Taxpayer works in the UK for more than 40 days per year.

Mr Taxpayer is UK tax resident and has 3 connecting factors. Mrs Taxpayer is UK resident and has 4 connecting factors.

They both recognise that, under the new FIG regime, they will be taxed in the UK on a worldwide basis. This would be a significant cost to them, and they would therefore like to reconsider their UK tax residence position.

However, they would still like to spend time in the UK, particularly Mrs Taxpayer who does not intend to end her UK consulting work.

To cease their UK tax residence, both their day count in the UK and their “connecting factors”, as specified in the UK Resident/Non-Resident Test, will need to be considered.

Question – Is it possible to maintain the same day count?

Answer – If they wish to retain their current UK day count, they would not be able to do so under any of the automatic non-residence tests and so they would both need to remove all connecting factors. However, this is not possible as they have already triggered the connecting factor of more than 90 days in the previous 2 tax years. It is therefore not possible to maintain this day count. 

Question –If all connecting factors are retained, how many days would they need to reduce their day count to?

Answer – Mr Taxpayer would need to reduce his day count to below 91 days. Mrs Taxpayer would need to reduce hers to below 46 days, which would prevent her from working her current number of days in the UK. It is worth noting that if they reduce their day count to this level, after 2 years, they will no longer trigger the “90 day” connecting factor. After 3 years, they will be considered “arrivers”, so additional planning options might be available at this time.

Question – How many days can they spend in the UK each year?

Answer – The connecting factors and their status as “arrivers” or “leavers” will change over the years and therefore each year will need to be considered separately.  If they are not prepared to sell the apartment and/or if Mrs Taxpayer intends to stop working as many days while in the UK (limiting work days to 40); the table below shows the maximum number of days they could spend in the UK while still meeting the requirement to lose UK tax residence for the full 10 year period.

	Year 1	Year 2	Year 3	Year 4	Year 5
Mrs Taxpayer	45	45	90	90	90
Mr Taxpayer	90	90	120	120	120

Question – How would their day count change if Mrs Taxpayer ceased working in the UK?

Answer – This would mean she would lose one of her connecting factors. Their day count would therefore mirror each other’s:

	Year 1	Year 2	Year 3	Year 4	Year 5
Mrs Taxpayer	90	90	120	120	120
Mr Taxpayer	90	90	120	120	120

Question – If Mrs Taxpayer does not want to reduce the number of days she works in the UK, but they sold their apartment and stayed in a hotel while in the UK, would this change their position?

Answer – Yes, if care was taken to ensure that this placed them in a position to avoid the accommodation connecting factor, they would both have lost one of their connecting factors:

	Year 1	Year 2	Year 3	Year 4	Year 5
Mrs Taxpayer	90	90	120	120	120
Mr Taxpayer	120	120	120	182	182

The Positive Effects of Tax Planning

The example of Mr and Mrs Taxpayer illustrates the complexities of the statutory residence test and how, for a married couple, joint planning is crucial. 

It also highlights how a single change (in this example, Mrs Taxpayer not working in the UK, or the apartment being sold) could allow them to become non-UK tax residents without significantly reducing their number of days spent in the UK.

Additional Information

If you require any additional information on this topic, please speak to Paul Webb at the Dixcart office in the UK: advice.uk@dixcart.com or to your usual Dixcart contact.

Background

“Don’t worry, I never spend more than 90 days in the UK”.

This test for UK tax residence was replaced with a statutory residence test, but it is still commonly believed that the above statement is correct.

It is not and, whilst in many cases, the test might result in an individual triggering UK tax residency without expecting it, in many other circumstances, they might have been limiting themselves to the wrong number of days.

For anyone renting or buying property in the UK and starting to spend more and more time in the UK, they should seek advice to be clear what their day pattern in the UK should or can be. This note considers a couple who have not previously been tax resident in the UK.  For more information about correctly losing UK tax residence, please see – Tax Residence Planning Opportunities – Case Studies and How To Get it Right. It also does not consider immigration but more information on how Dixcart can assist with UK Immigration can be found here – Dixcart Immigration.

Case Study

Mr Overseas has lived in Europe his whole life.  Having sold his successful overseas business a number of years ago, he took early retirement. He is not married.

Having retired, he wants to spend more time in the UK as he has nephews and nieces whom he enjoys seeing more of.

He also feels that the UK real estate market might be a good investment, so he purchases an apartment that he lives in when he is here.  It is empty the rest of the time.

Thinking he is doing some clever tax planning, he chooses to limit his days in the UK to 85-89 days, because everyone tells him that if he stays in the UK for fewer than 90 days, he won’t become tax resident. 

Mr O Should Take Some Advice!

The part of the UK statutory resident test (Test) relevant to him is part 3, the Connecting Factors.  In the first year he starts spending time in the UK, he does not have a tax resident family member, he has not exceeded 90 days in the UK in either of the two previous tax years, and he does not work in the UK for more than 40 days each tax year.  He does have available accommodation though, so he has just one Connecting Factor.  In the first year, he could spend up to 182 days in the UK without becoming UK tax resident, double what he had originally thought.

In the second year, he would still have available accommodation but also now would have spent more than 90 days in one of the previous two tax years.  His day limit is now 120 days, still more than the “90 days rule” he had been told about.

Once he discovers this, he starts spending up to 115-119 days in the UK

However – The Rules Need Constant Review

As Mr O is now spending more time in the UK, he meets someone special and gets married.  He also gets bored of early retirement and starts a consulting role for most of the days he is in the UK.

Thinking that he has now taken his UK tax advice about residence, he doesn’t think to check it again.

Mr O now has a tax resident spouse, he works for more than 40 days in the UK, he has spent more than 90 days in the UK in at least one of the last two previous tax years and he still has available accommodation.

His tax circumstances have changed dramatically and, in fact, if he wants to still remain non-resident in the UK, his day count would be capped at 45 days!

There is still planning to do though, as he might be able to claim the remittance basis as a non-domiciled individual. With the 2025 UK tax changes for non-doms and evolving rules around foreign income and gains, it’s important to understand the do’s and don’ts to ensure compliance and make informed decisions.

Summary and Additional Information

Whilst Mr O’s circumstances shifted during the course of this case study, it is interesting to note that at no point in time was Mr O’s day count cap at 90 days, despite the common belief that those are the rules for UK residence.

The remittance basis of taxation, which is available for non-UK domiciled individuals, can be a very attractive and tax efficient position, but it is crucial that it is properly planned for and properly claimed at the right time. 

If you require additional information on this topic, further guidance regarding your possible entitlement to use the UK remittance basis of taxation, and how to properly claim it, please contact your usual Dixcart adviser in the UK office: advice.uk@dixcart.com.

Dixcart UK, is a combined accounting, legal, tax and immigration firm.  We are well placed to provide these services to international groups and families with members in the UK. The combined expertise that we provide, from one building, means that we work efficiently and coordinate a variety of professional advisers, which is key for families and businesses with cross-border activities.

By working as one professional team, the information we obtain from providing one service, can be shared appropriately with other members of the team, so that you do not need to have the same conversation twice!  We are ideally placed to assist in situations as detailed in the case study above. We can provide cost effective individual and company administration services and also offer in-house expertise to provide assistance with more complex legal and tax matters.

An Introduction to Domiciliation

The Cyprus Non-Domicile regime (or non-dom) hinges on a person’s domiciliation. It is important to note that there are two kinds of domicile:

• Domicile of origin: The domicile assigned to an individual at birth.
• Domicile of choice: The domicile acquired by an individual through establishing a physical presence in a particular place, combined with the intention of making it their permanent home.

Individuals who have been tax residents in Cyprus for at least 17 out of the last 20 years will be deemed domiciled in Cyprus. Meaning, once you meet the 17-year limit, you will be considered to have a Cyprus domicile of choice.

Tax Residency

It is also important to note that the Cyprus tax regime only applies to individuals who are tax residents. Anyone looking to take advantage of the benefits under the non-dom regime must first ensure that they are a tax resident of Cyprus. You can find full details in our article on Cyprus Tax Residency.

Application, Cost and Evidence

Unlike other tax regimes around the world, the Cyprus non-dom regime has no participation cost and there is no minimum annual tax bill to be paid. In other words, there is no annual fee payable to the government in order to benefit from the advantages outlined below.

Applicants must complete the specified form and submit it along with evidence that they are tax residents of Cyprus and that their domicile of origin or choice is not Cyprus.

Once your application has been approved, you can request a certificate to confirm your tax residency and status as a non-domiciled individual. This certificate, issued by an EU member state government, can be used when required in other jurisdictions.

Benefits

Before diving into the benefits, it isworth remembering that Cyprus tax residents are taxed on their worldwide income. This means the following advantages apply to income sourced in Cyprus or remitted to Cyprus from abroad. Additionally, there are no wealth and no inheritance taxes in Cyprus, for both ordinary residents and non-doms.

Cyprus’ non-domicile status provides access to a range of highly attractive tax benefits. Individuals who qualify under the regime are exempt from income tax on the following:

• Interest
• Dividends
• Capital gains (excluding immovable property in Cyprus, which may still benefit from partial exemption on newly acquired property)

Non-doms in Cyprus also enjoy significant relief on their salaried income. Those who take up residency in Cyprus for the first time may be eligible for a 50% exemption on their salary from income tax. This is in addition to the standard 0% tax band.

To qualify for this exemption, individuals must meet the following criteria:

• Be a non-domiciled individual
• Be employed in their first job in Cyprus
• Earn an annual salary of €55,000 or more
• Be a “new resident” in Cyprus (meaning they must not have been a resident of Cyprus for a period of at least 15 consecutive tax years immediately prior to the commencement of their employment in Cyprus)

National Health Contribution

It is worth noting that both dividends and salaried income are subject to a General Health System (GHS) contribution of 2.65%, capped on income up to €180,000 per year. This means the maximum contribution is €4,770 annually. This contribution provides access to Cyprus’ excellent and comprehensive public healthcare system.

How Can We Help?

If you would like to know more about the Cyprus Non-Domicle Regime or if you have any questions about how we can help you, please contact us at the Dixcart office in Cyprus for further information: advice.cyprus@dixcart.com.

Our expert team can support you through every step, from immigration matters to tax residency and non-domicile applications. We can assist with compiling your supporting documentation, interpreting the governments forms. We will even attend the immigration office with you and can handle your annual tax return.

If you are planning to take advantage of the corporate benefits here in Cyprus as well by incorporating a company, we also offer a full range of corporate services including, but not limited to, company formation, secretarial support, and accounting services.

We provide end-to-end support at every stage, helping you successfully navigate Cyprus’ tax residency and compliance requirements, so you can make the most of Cyprus’ excellent tax benefits.

Tax Residency vs Legal Residency

Firstly, it is important to understand that tax residency and legal residency are two entirely different things and it is essential not to confuse the two.

In this article, we focus on what it takes to be considered a tax resident in Cyprus, something that has become increasingly popular thanks to several attractive schemes, such as the Cyprus Non-Dom Regime and the Flat Tax Regime For Overseas Pensions . You can find more details on these by clicking the relevant links.

The Two Tax Residency Rules

One of the key advantages of Cyprus’ tax residency system is its simplicity. There are only two rules, and no grey areas. You either meet the criteria or you do not. These are the 183-day rule and the 60-day rule.

183-day rule

This one is as straightforward as it sounds: if you legally reside in Cyprus for at least 183 days in a tax year, you are considered a tax resident, as long as you have evidence to support your stay.

60-day rule

The 60-day rule is one of the most attractive tax residency options in the world because it has such a short stay requirement. It does however come with a few additional conditions. To qualify, you must:

• Legally reside in Cyprus for at least 60 days in the tax year
• Be employed, self-employed, or a director of a company that is tax resident in Cyprus
• Own or rent a residential property in Cyprus for the whole tax year
• Not be tax resident in any other country
• Not spend more than 183 days in total in any one other country

This rule was introduced to attract business owners, consultants, and other mobile professionals who do not necessarily want or need to be based in one location year-round, but still want access to an advantageous, stable, EU-based tax residency.

This option is particularly popular with highly mobile individuals. It allows them to establish tax residency in Cyprus (and obtain a tax residency certificate) while still enjoying the freedom to travel extensively. All while benefiting from Cyprus’ fantastic tax regime.

Tracking Your Days and Proving Your Residency

As you would expect, you will need to prove how many days you have spent in Cyprus. The evidence required can vary depending on your lifestyle — someone living in Cyprus for 300 days a year will need to show different evidence than someone visiting four times a year for 15 days each time.

In addition to other documentation, the most commonly requested evidence includes:

Proof of legal residency:

• Passport or ID card
• Your immigration documentation (often referred to as the “Yellow Slip”)

Proof of days spent:

• Utility bills showing usage during the relevant periods
• Bank statements showing local spending
• For 60-day rule applicants: flight tickets proving entry and exit dates

Tax Residency Certificate

Once you are a Cyprus tax resident, either through the 60-day rule or the 183-day rule, you can request a Tax Residency Certificate. This certificate can be used in other jurisdictions to evidence your tax residency in Cyprus if needed.

How Can We Help?

If you would like to know more about Cyprus tax residency or if you have any questions about how we can help you, please contact us at the Dixcart office in Cyprus for further information: advice.cyprus@dixcart.com.

Our expert team can support you through every step, from immigration matters to tax residency applications and compiling your supporting documentation. We will even handle your annual tax return.

If you are planning to take advantage of the 60-day rule, we also offer a full range of corporate services including, but not limited to, company formation, secretarial support, and accounting services.

We provide end-to-end support at every stage, helping you successfully navigate Cyprus’ tax residency and compliance requirements, so you can make the most of Cyprus’ excellent tax benefits.