Key Employee Initiative – Fast-track Work Permit in Malta for Non-EU Highly-Skilled Workers

What is the Key Employee Initiative?

The Key Employee Initiative (KEI) provides a fast-track work permit for highly specialised Third-Country Nationals (TCNs), who are employed in Malta.

The scheme enables work permits to be issued to key prospective employees, no longer than 5 working days from the date of application, under normal circumstances.

Third-Country Nationals

Third-Country Nationals require a single work permit to be able to obtain residence and be employed in Malta. This is because TCNs are not members of the EU or EFTA, and are therefore not able to move across borders, in the EU, without the proper documentation. 

However, TCNs who are high-skilled workers, are provided with a fast-track work permit service by the Key Employee Initiative. Under normal circumstances, the scheme will issue work permits in not more than 5 days, as detailed above. In contrast non highly specialised TCNs must wait for at least a couple of months.

Who is Defined as a Highly Skilled Worker?

Highly-skilled workers include individuals who possess advanced technical, academic and interpersonal skills. They usually flourish in the areas of; problem-solving, leadership, system improvement and creativity. Examples of highly-skilled workers include; university professors, engineers, biotech scientists, business directors, and IT experts. 

Criteria

Maltaโ€™s Key Employee Initiative (KEI), is available to highly technical or managerial professionals with the relevant qualifications and experience for the job they are applying for.

Eligible highly-skilled workers are required to meet the following requirements: 

  • Have valid travel documents.
  • Receive an annual gross salary of at least โ‚ฌ35,000.
  • Be in possession of certified copies of qualifications and necessary work experience.
  • The employer must declare that the individual has the necessary credentials for the assigned role. Should the applicant wish to be employed by a Maltese company of which s/he is a shareholder or ultimate beneficial owner, s/he must have a fully paid up share capital of at least โ‚ฌ500,000 OR must have made a capital expenditure of at least โ‚ฌ500,000 to be used by the company (fixed assets only, rental contracts do not qualify).

Benefits:

The following benefits are available through Maltaโ€™s Key Employee Initiative:

  • The KEI is a fast-track version of the standard single work permit application, with applications being approved in just 5 days.
  • Applications can be submitted online, without the applicant needing to be present in Malta.
  • Approved applicants are issued with a residence permit valid for 1 year. This  can be renewed, subject to the presentation of a valid definite or indefinite contract, and an original โ€˜annual tax declaration formโ€™, stamped by the Maltese Inland Revenue Department.
  • Visa-free travel within the 26 Schengen Area Countries, by virtue of the Maltese residence card. This is limited to a maximum of 90 days every 180 days.

Family Members of Work Permit Holders

Non-EU nationals who have been legally residing in Malta for over a year (in specific circumstances this may be reduced), are eligible to apply for the โ€˜reunificationโ€™ of family members. This includes spouses over the age of 21 and children under the age of 18.

Long-term Residents

Long-term residence status may be granted to persons legally residing in Malta for a continuous 5 year period.

A successful application requires; proof of continuous residence prior to the application date, and the ability to show stable and regular income of a stipulated amount. Dixcart can provide details of the other requirements, which include the need to have health insurance and attendance of a language and culture course.

Tax Treatment

  • Tax is charged at progressive rates (capped at a maximum of 35%), on Malta sourced income and capital gains, and on foreign source income (excluding foreign source capital gains), that is remitted to Malta.
  • No tax is chargeable on foreign sourced income that is not remitted to Malta.
  • Capital gains are tax-exempt in Malta, even if they are remitted to Malta.
  • Bank interest earned in Malta can be liable to withholding tax at 15%.
  • Long term residence permit holders are not entitled to benefit from the remittance basis of taxation and will be taxed on their worldwide income in Malta.

Case Study

Dixcart Malta provided advice to a UK citizen who was still living in the UK. An important benefit of the Key Employee Initiative is that it is possible to start the  process before the relevant individual has even arrived in Malta.

This highly-skilled professional, in the ICT industry, secured his position at a Maltese employer and decided to relocate to the island once he received the โ€˜Approval in Principal Letterโ€™, confirming that his application met all of the requirements and had been successful.

After being provided with all of the essential documents, Dixcart Malta made the application, on behalf of the Employee and Employer and submitted all of the forms and evidence of experience, qualifications, and health insurance, to the Authorities. In addition, we even helped to find an apartment for the newcomer.

After receiving a final decision, the KEI had 90 days to relocate to Malta.

Another Set of Circumstances

Dixcart Malta can also provide support services, relating to the Key Employee Initiative, for TCN Employees and local Employers. There may be situations where positions cannot be filled by the local labour market and where suitable TCNs can fulfil the job in the EU with a fast-track Malta work permit, rather than the company remain with vacant positions.

Additional Information

For further information on the Key Employee Initiative, please do not hesitate to contact Jonathan Vassallo: advice.malta@dixcart.com at the Dixcart office, in Malta or your usual Dixcart contact.

Dixcart Management Malta Limitedย Licence Number: AKM-DIXC.

New More Accessible Fast-Track Work Permit in Malta

The Specialist Employee Initiative

A new Fast-track work permit has been introduced in Malta called the Specialist Employee Initiative (SEI). This route is applicable to specialised employees that are not eligible for the Key Employee Initiative (KEI), but still hold the relevant academic, vocational or technical skills in line with their employment offer in Malta. Applications for SEIs are filed in accordance with the Single Permit Regulations.

The introduction of the SEI demonstrates Maltaโ€™s commitment to attracting global talent, recognising the importance of simplifying application procedures for qualified foreign workers.

Third-Country Nationals

Third-Country Nationals (TCNs) require a single work permit to obtain residence and to be employed in Malta. This is because TCNs are not members of the EU or EFTA, and are therefore not able to move across borders, in the EU, without the proper documentation.

However, highly skilled TCNs benefit from a fast-track work permit service under this Specialist Employee Initiative.

Application Process

The processing time for this type of application typically takes around 15 days, after submission of the complete list of required documents.

The employer is required to email a completed application along with all necessary attachments in accordance with the relevant checklist. โ€˜Identitรกโ€™, the Government Agency overseeing this programme, will ask the applicantโ€™s permission before submitting the application and supporting materials.

Upon receiving approval, the application will be processed in accordance with set protocols. Both the company and the candidate will receive an informational email and an acknowledgement, along with additional instructions on how to pay the application fee during the biometrics stage.

Any missing documents can result in delays or application rejection. It is important to ensure that all mandatory documents are submitted as per the checklist.

Once a decision is made on the application, both the applicant and the employer are informed of the outcome via email.

Eligibility and Requirements

In order to be eligible to apply for the SEI application an individual must:

  • Have a signed contract with a Maltese company;
  • Have an annual gross salary of at least โ‚ฌ25,000;
  • Be in possession of either
    • (i) an MQF level 6 or higher in an area directly related to the job offer or
    • (ii) skill qualifications together with a minimum of 3 yearsโ€™ experience in a position which is directly related to the job offer.
  • Present previous employment contracts (signed by both employer and employee).
  • Provide their employment history, issued and officially certified (stamped or legalised) by the official employment authority in the country where the employment took place.
  • Reference letters by former employer/s. Reference letters must show the start and end dates and details of the work carried out. The letters should contain clear contact details of the referee including a valid email address, postal address and contact number.

Typical documents needed with the application are:

  • Full copy of passport
  • CV
  • Declaration of Suitability
  • Lease Agreement & Housing Approval
  • Health Screening
  • Health Insurance

Visa duration and conditions

A residence permit will be granted to successful applicants for a period of one year. If the employee remains in compliance with the eligibility criteria and his/her employment contract applies to all periods of validity, this authorisation may be renewed for an additional period of up to three years.

Tax Treatment

  • Tax is charged at progressive rates (capped at a maximum of 35%), on Malta sourced income and capital gains, and on foreign source income (excluding foreign source capital gains), that is remitted to Malta.
  • No tax is chargeable on foreign sourced income that is not remitted to Malta.
  • Capital gains are tax-exempt in Malta, even if they are remitted to Malta.
  • Bank interest earned in Malta can be liable to withholding tax at 15%.
  • Long-term residence permit holders are not eligible for the remittance basis of taxation and will be taxed on their worldwide income in Malta.

Conclusion

The introduction of this programme introduces an option for highly skilled third country nationals to obtain a work and residence permit in Malta, 15 days after the submission of the application and relevant documentation. Identitรก have recognised the increased demand for such a work permit and this initiative will help improve processing time and efficiency.

Additional Information

For further information on the Specialist Employee Initiative, please do not hesitate to contact Jonathan Vassallo: advice.malta@dixcart.com at the Dixcart office, in Malta or your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC.

UK Non-Domiciled Individuals Seeking to Relocate to Cyprus

Introduction

Following the announcement in March 2024 from the UKโ€™s Treasury Department, that the current UK non-domiciliation rules will cease to exist from 6 April 2025, many UK non-domiciled residents may start the decision process to relocate to tax efficient jurisdictions

The Benefits of Cyprus

  • attractive tax incentives for individuals wishing to become Cyprus residents.
  • excellent education infrastructure
  • reasonable cost of living
  • high quality public and private health care services
  • advanced infrastructure of services
  • a warm and friendly community in which to live.
  • simple tax regime that is fully EU and OECD compliant
  • well drafted laws on Corporate and Commercial matters
  • easy access to international litigation and arbitration

And last but not least, the excellent weather with beautiful surroundings and culture.

Moving to Cyprus

There are various options in terms of moving to Cyprus, as outlined below:

EU non-domiciled UK residents moving to Cyprus.

All nationals of the Member States of the European Union have the right to move freely within the European Union and to enter and reside in any EU Member State. This right to freedom of movement is guaranteed by article 21 of the treaty on the functioning of the EU (TFEU).

EU and EEA Citizens entering Cyprus to work, stay or remain as visitors for more than 3 months on the island need to register for a residence permit for EU citizens. The registration certificate they get is commonly known as Yellow Slip.

Third country non-domiciled UK residents moving to Cyprus.

A. Moving to Cyprus, from the UK, as an Investor

The recently revised Residency by Investment programme allows foreign nationals to obtain permanent residency by investing in a Cypriot property worth at least โ‚ฌ300,000, plus VAT. Applicants must also have an annual income of at least โ‚ฌ50,000 plus โ‚ฌ15,000 for a spouse and โ‚ฌ10,000 for each dependent child or family member included in the application.

The applicant and his spouse/husband must certify that they do not intend to be employed in the Republic of Cyprus except for their employment as Directors in a Company in which they have chosen to invest within the framework of the policy, as detailed below.

B. Living in Cyprus with a Temporary Residence Permit

1. Establishment of a Foreign Interest Company.

A Foreign Interest Company is an international company, which, subject to meeting specific criteria, can employ non-EU national employees in Cyprus. This programme enables employees and their families to gain residence and work permits under favourable terms.

The Main Requirements Enabling an International Company to Qualify as Foreign Interest Company

  • The third country shareholder(s) must own more than 50% of the total share capital of the company.
  • There must be a minimum investment of โ‚ฌ200,000 or โ‚ฌ260,000 (depending on the circumstances) into Cyprus by the third country shareholder(s). This investment can be used later to fund future expenses incurred by the company when it is established in Cyprus.
2. Acquiring a temporary residence permit as an employee at a Foreign Interest Company.

Employees at Foreign Interest Companies and their family members can acquire temporary residence and work permits which are renewable.

3. Temporary / Retirement / Self-Sufficiency Residence Permit

The Cyprus Temporary Residence Permit is an annually renewable self-sufficiency visa that allows an individual and their qualifying dependants, to live in Cyprus as a visitor, without employment rights.

The main qualification requirements are as follows:

  • Annual income, that is sourced from outside Cyprus, of a minimum of โ‚ฌ24,000, which increases by 20% for a spouse and by 15% for each dependent child.
  • A title deed or rental agreement for a residential property in Cyprus that is for the sole use of the applicant and his/her family.
  • A certificate of โ€˜no criminal recordโ€™ and of not being under investigation for criminal offences, that is certified, by the relevant authorities of the applicantโ€™s country of current residence.
  • Private medical insurance.
  • An original medical examination certificate to confirm that the applicant does not have certain medical conditions.

It is essential that the holder of a Cyprus temporary residence permit should not stay outside of Cyprus for more than three months at a time, because this could result in the permit being cancelled.

Additional Information

For further information about the attractive tax regime for individuals in Cyprus please contact the Dixcart office in Cyprus: advice.cyprus@dixcart.com.


Lisbon

Starter Kit for Indian Individuals Interested in a Portuguese Golden Visa Fund

Understanding the Portuguese Golden Visa Fund

The Portuguese Golden Visa Fund is an investment option that allows non-EU citizens, including Indians, to obtain a Portuguese residence permit. This residence permit provides visa-free travel within the Schengen Area, the right to live, work, and study in Portugal, and a path to Portuguese citizenship after five years.

I thought that the Portuguese Golden Visa had Ended?

Following a recent restructure of the programme, certain routes are no longer available, as finally voted on the 21 of September 2023. The new programme changes what types

of investment qualify for the scheme; real estate and capital transfer investments are no longer eligible.

What is a Collective Investment Entity (CIS)?

A Collective Investment Entity (CIS) is a type of investment fund that pools money from multiple investors, to invest in a diversified portfolio of assets.

To qualify for the golden visa, the CIS must be established under Portuguese legislation, with a length of maturity of at least five years, and with at least 60% of the value of the investments being made in commercial companies headquartered in the national territory of Portugal. A CIS is regulated by an independent body, which overseas such funds, and is known as the Portuguese Securities Market Commission (CMVM โ€“ Comissรฃo do Mercado de Valores Mobiliรกrios).

Evaluating a Good Investment Entity

When evaluating a CIS for the Portuguese Golden Visa, consider the following factors:

  • Track record: Choose a CIS with a proven track record of generating returns
  • Investment strategy: Understand the CIS’s investment strategy and ensure it aligns with your risk tolerance.
  • Fees: Compare the fees charged by different CISโ€™s.
  • Regulatory compliance: Verify that the CIS is fully compliant with Portuguese
  • regulations.
  • Management team and expertise: definitely consider experience to date.

Examples of Investments Made by CISs

CISs invest in a variety of asset classes, including private equity, where companies, with a mature profile or promising growth, are invested in. Specific examples include; operating hotels and resorts, solar project developments, annual crop yield improvement projects, farm development, amongst many examples. There is an investment for almost every interest!

Tangibility and Risks of a CIS

CISs are intangible assets, meaning they do not have a physical form. However, they represent ownership in a portfolio of tangible assets. Investing in a CIS involves risks, including:

  • Market risk: The value of a CIS investment can fluctuate with market conditions.
  • Credit risk: There is a risk that the companies or securities invested in, by the CIS, may default on their obligations.
  • Liquidity risk: There may be a delay in selling your investment in a CIS.

Comparability to other EU Residency Programmes

The Portuguese Golden Visa Fund offers several advantages when compared to  other EU residency programmes, including:

  • Lower investment requirement: The minimum investment for the Portuguese Golden Visa Fund is โ‚ฌ500,000, which is lower than the investment requirements for many other EU passport programmes.
  • Flexibility of stay: You are only required to spend seven days per year in Portugal to maintain your residence permit.
  • At the end of five years of legal residency, you can apply for a Portuguese passport, which is not permitted in all of the other residency programmes available in the EU.

Navigating Indian Exchange Control Issues

Indian residents are subject to exchange control regulations that restrict the amount of foreign exchange they can transfer out of the country. Dixcart Portugal Lda has assisted many Indian clients with their investments in Portugal, and you are welcome to discuss such matters with us.

Portugal โ€“ A preferred Route for Indian Nationals?

According to the Portuguese Immigration Authorities, as of October 2023, a total of 1,234 Indian nationals have applied for the Portuguese Golden Visa. This represents almost 5% of all Golden Visa applications received to date!

It is therefore not surprising that, there is a large and growing Indian community in Portugal.

How to choose the right partner for your Portuguese Golden Visa?

When selecting a partner to assist with your Portuguese Golden Visa, consider their; experience, reputation, communication, fees, location, and expertise in your investment type. Additionally, try to ensure that they are responsive, keep you updated, and can explain complex concepts clearly.

Dixcart Portugal Lda: Your Experienced Partner for the Portuguese Golden Visa

Dixcart Group has over 50 years of experience, with 35 years of experience in Portugal, working with private clients and advising corporates. We are headquartered in the UK and have a proven track record. We have clientele based all over the world โ€“ including a substantial client book of business from India.

We have also been able to refer specific cases to the right legal team in instances  where biometrics have been lost, or other challenges have arisen, such as missed biometric appointments. These are special cases which require expertise and experience to manage successfully โ€“ which we have been able to achieve to date.

Dixcart Portugal Lda were one of the first companies to coordinate and help manage golden visa applications, through introductions to Portuguese legal advisers, who have assisted many individuals and families to complete the programme and obtain a Portuguese passport. In addition, Dixcart Portugal Lda already have experience of the many changes that have been made to the programme over time, and have helped clients deal with these revisions.

Contact Dixcart Portugal Lda Today to Learn More

If you are an Indian individual interested in a Portuguese Golden Visa Fund, please contact Dixcart Portugal Lda today, to learn more about your options and how we can help you achieve your immigration goals and connect you with the right legal advisers: advice.portugal@dixcart.com

Tax Efficiencies Available in Cyprus: Individuals and Corporates

Why Cyprus?

Cyprus is an appealing European jurisdiction, located in the eastern Mediterranean Sea offering a warm climate, attractive beaches and the perfect balance of cosmopolitan living and rural villages. Strategically located at the crossroads of three continents, Cyprus is accessible from Europe, Asia and Africa. Nicosia is the centrally located capital of the Republic of Cyprus however, the growing financial hub is Limassol on the southern coast. The official language is Greek, with English also being widely spoken. Cyprus offers a palette of both corporate and personal tax incentives for expatriates and high net worth individuals relocating to Cyprus. Cyprus has a favourable business environment and, as a result, has become an attractive an international business hub.

Are you looking to relocate your business and/ or start a new business in Cyprus? Maybe youโ€™re considering setting up a holding company or restructuring the fiscal position of a family office structure? If you are, please consider the below information and become convinced of a great way to optimize your business structure We will start by looking at the tax benefits available to individuals and to corporates.

Tax Benefits Available to Individuals

What are the Advantages of Becoming Cyprus Tax Resident?

Cyprus non-domicile status can be an effective means to optimise personal wealth planning. The advantages of becoming Cyprus tax resident, an option for individuals not previously tax resident in Cyprus, include the following:

  1. Non-Domicile Status

The non-domicile tax regime is particularly interesting for individuals whose main source of income is either dividend or interest income, as these sources of income are not taxed in Cyprus.

Individuals can also take advantage of the exemption from taxation of capital gains, other than on the sale of immoveable property in Cyprus.

In addition, there is an exemption from taxation on capital sums received from pensions, provident and insurance funds as well as several other tax advantages, including; a low rate of tax on foreign pension income, and no wealth or inheritance taxes in Cyprus.

The zero tax benefits, mentioned above, are enjoyed even if the income has a Cyprus source and/or is remitted to Cyprus.

  1. Employment Income Tax Exemption

New incentives for first employment in Cyprus

The 50% exemption:

As from 1 January 2022, 50% of the remuneration of employees whose first employment in Cyprus began on, or after, 1 January 2022 is exempt from income tax for a period of 17 years, provided that their annual remuneration exceeds โ‚ฌ55,000 (previous threshold โ‚ฌ100,000), and the employees were not residents ofย Cyprus for a period of, at least, 15 consecutive years before the commencement of their employment in Cyprus.

In cases where in a tax year the relevant conditions are not satisfied (e.g., annual remuneration is less than โ‚ฌ55,000) the above-stated exemption will not be granted for that specific tax year. This exemption is available for a period of up to 17 years.

The 20% exemption:

Individuals whose first employment in Cyprus began after 26 July 2022 and earn less than โ‚ฌ55,000 are eligible for a 20%, or โ‚ฌ8,550 exemption (whichever is lower) from their employment income, for a maximum period of 7 years provided that the employees were not residents ofย Cyprus for a period of, at least, 3 consecutive years before the commencement of their employment in Cyprus.

This exemption can be claimed from the year following the year of commencement of employment in Cyprus.

  1. Tax Exemption on Income from Employment Outside Cyprus

Individuals who are employed outside of Cyprus, for more than 90 days in aggregate in a tax year, by a non-Cyprus tax resident employer or foreign permanent establishment of a Cyprus tax resident employer, are exempt from income tax on this income.

Tax Benefits Available to Companies

  1. Corporate Tax Rate

Cypriot companies enjoy a 12.5% rate of tax on trading, and a zero rate of capital gains tax.

  1. NID

NID is deducted from taxable income. It cannot exceed 80% of the taxable income, as calculated prior to the NID, arising from the new equity.

A company could achieve an effective tax rate as low as 2.50% (corporate tax rate 12.50% x 20%). Please contact the Dixcart office in Cyprus for further information: advice.cyprus@dixcart.com

  1. Increased Tax Deduction for Research and Development Expenses

ย Eligible research and development expenses can be deducted from taxable income equivalent to 120% of the actual spend.

Additional Information

For further information about the attractive tax regimes available to individuals and companies in Cyprus, please contact the Dixcart office in Cyprus:ย advice.cyprus@dixcart.com.

ย 

The Ultimate Guide to Relocating to Switzerland

Switzerland, with its snow-capped peaks, pristine lakes, and efficient infrastructure, has long been a dream destination for many individuals seeking a balance between a high-quality lifestyle and professional opportunities. As one of the most prosperous and picturesque countries in Europe, it also attracts individuals due to its strong economy, political stability, and exceptional living standards. If you are considering making Switzerland your new home, here’s the ultimate guide to navigating the logistics of working and living in this alpine haven.

You may find also find this Dixcart Swiss Article of interest to read: Switzerland – Could this be your Next Move? – Dixcart

Relocating Logistics

Visa and Residency

Before planning your move, it is essential to understand Switzerland’s visa and residency requirements. Depending on your nationality and purpose of stay, you might need to obtain a visa or a residence permit. Ensuring you have the necessary paperwork in order, will smooth the transition process.

Accommodation

Switzerland boasts a diverse housing market, from urban apartments to picturesque countryside chalets. Local real estate agents and online platforms can help you find the perfect place to call home.

Healthcare System

Switzerland is renowned for its excellent healthcare system, which is often ranked among the best in the world. Familiarise yourself with the country’s health insurance requirements and the different insurance providers available, to ensure that you and your family have comprehensive coverage.

Working in Switzerland

Job Market

Switzerland is home to a thriving economy, particularly in sectors such as finance, pharmaceuticals, and technology. Understanding the job market, networking with professionals in your field, and researching employment opportunities will increase your chances of finding a fulfilling career.

This Dixcart Article includes a useful section regarding working in Switzerland: How Can I Relocate to Switzerland and What Help is Available? – Dixcart

Work Culture

Swiss work culture is known for its punctuality, precision, and strong work ethic. It’s crucial to familiarise yourself with the local customs and etiquette, including the importance of maintaining professionalism and respecting hierarchical structures within the workplace.

Taxes and Finance

Switzerland has a well-established tax system, but it can be complex for newcomers. Educate yourself on the tax regulations and financial planning to ensure compliance and make the most of the various benefits offered to residents.

It is worth seeking professional advice and the Dixcart office in Switzerland can help guide you regarding the various taxes: advice.switzerland@dixcart.com

Living in Switzerland

Cultural Immersion

Embrace the Swiss way of life by participating in local cultural activities, festivals, and events. Learning one of the country’s official languagesโ€”German, French, Italian, or Romansh can also help you integrate more seamlessly into the community.

Outdoor Lifestyle

Switzerland’s breathtaking natural landscapes offer an abundance of outdoor activities, from skiing and snowboarding in the winter to hiking and swimming in the summer. Embrace the Swiss passion for nature and adventure by exploring the countryโ€™s extensive network of hiking trails and ski resorts.

Community Engagement

Swiss communities value active participation and engagement. Get involved in local community initiatives, clubs, or volunteer organisations to build meaningful connections and foster a sense of belonging in your new surroundings.

For Expert Assistance, Reach Out to advice.switzerland@dixcart.com

Relocating to Switzerland can be a rewarding and enriching experience, but it requires thorough preparation and a comprehensive understanding of the country’s customs, laws, and lifestyle.

For personalised guidance and professional support in navigating the intricacies of the relocation process, reach out to our expert advisers at advice.switzerland@dixcart.com. Our team at Dixcart Switzerland is dedicated to ensuring a seamless transition and helping you make the most of your Swiss adventure.

Malta

Moving to Malta โ€“ Using the Isle of Man to Structure Your Assets Efficiently

Located in the heart of the Mediterranean, between the north of Africa and southern Europe, Malta is a modern international commercial hub with a global draw.

Malta boasts a diverse economy with well-developed Financial Services, Fintech, Science and Technology, eGaming, Maritime Services and Aviation sectors. Additionally, the island offers extensive Residency routes available, Schengen area status, fantastic travel links and potentially beneficial tax regime. For these reasons and many more, Malta is a destination of choice for wealthy families, entrepreneurs and businesses around the world. 

Malta offers people relocating to her shores a very attractive Non-Domicile regime that provides individuals with a great deal of flexibility when it comes to structuring their financial matters โ€“ this is precisely where the Isle of Man can offer clients a platform for optimising their wealth.

In this article we take a brief look at how Dixcart can assist with moving to Malta and how those individuals can utilise the Isle of Man to protect and grow generational wealth, covering:

  1. How to Become a Maltese Tax Resident?
  2. What are the Tax Rules of the Maltese Non-Domicile regime?
  3. How Maltese Non-Domicile Individuals Utilise the Isle of Man for Wealth Planning?
  4. How Dixcart can Support your Move to Malta & Wealth Planning Goals

1. How to Become a Maltese Tax Resident?

There are two distinct groups of people when we consider the method of becoming Malta Tax Resident โ€“ these are 1) EU / EEA / Swiss Nationals, and 2) Third Country Nationals. Importantly, for the purposes of this article, where either type of individual does not intend to remain in Malta permanently and has no substantial connection to Malta, both groups may be deemed a Tax Resident Non-Domiciled individual. There are also compelling Residency Programmes available to each group which offer the same benefits and broadly have the same requirements.

Malta is a member of the European Union (EU) and European Economic Area (EEA). As such, EU / EEA Nationals can live, work and study in Malta indefinitely without a Visa or Work Permit. Swiss Nationals also enjoy this right. These individuals can apply for the Residence Programme via an Authorised Registered Mandatory, such as Dixcart Malta. The Residence Programme offers a special tax status to successful applicants who meet the requirements.

Third Country Nationals will be required to take part in a programme such as the Global Residence Programme or successful applicants also gain a special tax status and are granted a residence permit which also extends to their dependents, including spouses and children. The special tax status received under either programme entitles the individual to a beneficial flat rate of 15% on foreign source income remitted to Malta, with the possibility of claiming double taxation relief where an appropriate Double Tax Treaty is in place. Income that arises in Malta is taxed at a flat rate of 35%. The beneficial rate is subject to a minimum yearly tax contribution of โ‚ฌ15,000.

The Malta Residency Programme and Global Residence Programme requirements include:

  • Applicants must pay a one-time non-refundable registration fee of โ‚ฌ6,000 to the Maltese Government. This is reduced to โ‚ฌ5,500 where the Qualifying Property Holding is purchased in Gozo or the South of Malta.
  • Not have benefitted from a number of previous or existing Malta regimes.
  • Evidence of a Lease Agreement and Rental Declaration, or Purchase Agreement relevant to a Qualifying Property Holding. A Qualifying Property Holding requires a minimum investment in a Maltese property of โ‚ฌ275,000, or โ‚ฌ220,000 if the property is in Gozo or the South of the island. In the instance of a Rental Agreement, rent must cost not less than โ‚ฌ9,600 per annum, or โ‚ฌ8,750 if the property is in Gozo or the South of the island. The property cannot be let or sub-let.
  • Evidence of self-sufficient means of subsistence (e.g. bank statements, pension, secure bonds, etc).
  • Posses a valid travel document.
  • Evidence of comprehensive health insurance OR Certificate of Entitlement issued by the Entitlement Unit. Must provide cover within the EU for the applicant and all dependents.
  • Be proficient in one of Malta’s official languages (English is an official language of Malta).
  • Applicants and dependents over 18 years of age must satisfy the fit and proper person requirements.
  • Submit an Annual Return โ€“ with any material changes that affect the beneficiaryโ€™s special tax status.
  • Not spend more than 183 days in any other jurisdiction, in any single calendar year.

2. What are the Tax Rules of the Maltese Non-Domicile regime?

Liability to Maltese Income Tax arises in three forms, dependent on the Tax Residency and Domicile status of the individual โ€“ these are on a Worldwide, Remittance or Territorial basis.

Ordinary Residents of Malta who are Tax Resident and Domiciled are taxed on their worldwide assets; meaning that all Income and Capital Gains are subject to Maltese taxation regardless of where they arise or are received. This also applies to persons who hold the status of Long-term Resident or are in possession of a Permanent Residence Certificate or a Permanent Residence Card.

Maltese Ordinary Residency status is determined by a question of fact, relating to the length of stay along with personal and economic ties. Factors which the authorities will consider, include:

  1. Permanent or Indefinite Basis: Individuals living in Malta permanently or for an indefinite period are typically considered ordinarily resident.
  2. 183 Day Requirement: If an individual stays in Malta for more than 183 days in a single year they may be deemed Ordinary Resident.
  3. Regularity of Stays: Persons who do not meet the 183-day requirement, but who regularly visit over a long period of time e.g. over 3 years, can also be considered Ordinarily Resident.
  4. Personal and Economic Ties: Establishing personal and economic ties in Malta is a significant factor in determining Ordinary Residency e.g. purchasing a family home etc.

The Maltese authorities do not define Domicile by nationality, but where the individual considers their permanent Home i.e. where the person โ€˜belongsโ€™, which implies more significant ties than Residency alone. This can be the individuals Domicile of Origin i.e. normally the Domicile of their parents, regardless of the country where the individual is born. An individual may acquire a Domicile of Choice if they take up Residence in a country with the intention of making it their permanent home. However, they do not acquire Domicile status if they intend to return to their country of Domicile or resettle in another someday, even where the period is long or indefinite. No person can be without a Domicile, and no person can have more than one Domicile at the same time.

A person that is an Ordinary Resident but not Domiciled in Malta is taxed under the Remittance Basis, and therefore:

  • All income arising in Malta is subject to tax, regardless of where it is received.
  • Income arising outside Malta is subject to Maltese tax only if and to the extent that it is received in Malta.
  • Capital gains arising outside Malta are not subject to tax, even if they are received in Malta.

Individuals taxed under the Remittance Basis are subject to the special rule providing for a minimum tax liability of โ‚ฌ5,000 per annum (this minimum tax is different to the Global and Residence program which is 15%).

Unlike many equivalent Non-Domicile regimes, an individual can remain Non-Domiciled in Malta indefinitely.

This means that where the Tax Resident Non-Domiciled individual can show that monies received in Malta originate from assets held abroad as capital e.g. inheritance, proceeds from the sale of capital assets etc. they will be regarded as remittances of capital and will not suffer Maltese tax.

Dixcart Malta are equipped to provide Tax Advice regarding Maltese taxation and the Maltese Non-Domicile regime. If you would like to discuss how the regime works and any opportunities relevant to your circumstances, please get in touch with Jonathan Vassallo at Dixcart Malta.

3. How Maltese Non-Domicile Individuals Utilise the Isle of Man for Wealth Planning?

The Isle of Man is globally recognised as an international financial centre of excellence, boasting a sophisticated legal and regulatory system, a developed professional services industry and a long running heritage in Private Client and Corporate planning.

The Isle of Man was named โ€˜Best International Financial Centreโ€™ at the prestigious International Investment Awards 2023, beating off stiff competition from Jersey and Guernsey.

The island is a self-governing Crown Dependency which makes its own laws. The Statute book and Case Law is modern and business friendly yet enduring, with a wide array of corporate entities and Trusts available. The jurisdiction is also politically agnostic and therefore clients can take comfort from the stability and reliability offered.

The island also sets its own tax regime and offers headline rates which include:

  • 0% Corporate Tax
  • 0% Capital Gains Tax
  • 0% Inheritance Tax
  • 0% Withholding Tax on Dividends
  • Isle of Man companies are able to register for VAT, and businesses in the Isle of Man fall under the UKโ€™s VAT regime.

Owing to the attractive neutral tax regime, Non-Domiciled individuals seeking to live and work in Malta can potentially structure their non-Maltese assets in such a way that facilitates optimal growth via a potential nil rate in the Isle of Man, remitting withdrawals of capital to Malta free from Maltese taxation. Jonathan Vassallo at Dixcart Malta can provide certainty regarding the Maltese tax treatment of your potential Isle of Man structuring in this regard.

Taxation is a complex area and professional Tax Advice should always be sought before establishing any offshore structure.

4. How Dixcart can Support your Move to Malta & Wealth Planning Goals

After more than 50 years, the Dixcart Group remains proudly privately owned by the same family. the Group consists of 10 offices in 9 jurisdictions across the globe, including both Malta and the Isle of Man. Dixcart are very well positioned to assist clients and their advisers who are considering moving to Malta and seeking to structure their non-Maltese assets, or participation within a Maltese business, in a tax efficient manner via an Isle of Man structure.

Dixcart Malta are experts in all Residency programmes available and are Licensed to act as Authorised Registered Mandatory for clients wishing to apply for either the Malta Residence Programme for EU / EEA / Swiss Nationals, or the Malta Global Citizenship Programme for Third Country Nationals. Further, Dixcart Malta can provide Tax Advice for those looking to take advantage of the very beneficial Non-Domicile regime within Malta.

Dixcart Isle of Man are a Licensed and Regulated Trust and Corporate Services Provider that has developed an extensive range of services over its 30+ years of operation. Our team on the Isle of Man consists of professionally qualified experts and senior employees who possess a wealth of experience. This means that our Isle of Man office can support your corporate and/or Trust planning, at every stage.

Get in Touch

If you would like to discuss how our Dixcart can support your plans regarding Malta and the Isle of Man, please feel free to get in touch withย Jonathan Vassallo of Dixcart Malta or Paul Harvey of Dixcart Isle of Man via:

Dixcart Malta: advice.malta@dixcart.com

Alternatively, you can connect withย Jonathan Vassallo on Linkedin.

Dixcart Isle of Man: advice.iom@dixcart.com

Alternatively, you can connect withย Paul Harvey on LinkedIn.

Dixcart Management (IOM) Limited is Licensed by the Isle of Man Financial Services Authority

Dixcart Management Malta Limited Licence Number: AKM-DIXC-23

Which Portuguese Visa Option is Your Key to the Perfect European Adventure?

Choosing the right visa requires more than a quick chat and good cup of coffee to decide what is best for you, and getting in touch with the right person is the most important step.

To get you off to the right start, we have put together details of the differences between some of Portugalโ€™s most popular visas, to help you choose Portugal as a destination to live, work and play. You can also click into each visa for more comprehensive details.

  GOLDEN VISA D2 VISA D7 VISA DIGITAL NOMAD VISA
Eligibility Non-EU/EEA National
Time to Get Almost 2 years 5 to 8 months
Eligibility for the Visa Investment under the Portuguese law Incorporating a company or independent activity Passive income, such as pensions, or dividends Work contract or service provision contract
Investment Required From €200,000 Incorporation of a company N/A  
Specific Requirements Investment Investment activity Passive income of at least the amount of the minimum wage Salary of at least 3x the minimum wage over the last 3 months (average)
Minimum Stay Requirements 7 days per year Not being absent from the country for more than 6 months in a row or 8 months over 24
Citizenship After 5 years of legal residency
Travel Benefits Visa-free entry to the Schengen Area
Tax Implications Depends Tax resident – taxed on a worldwide income basis; Possibility to apply for the Non-Habitual Resident Regime

Reach out to Dixcart for more information – advice.portugal@dixcart.com.

Malta

The Benefits of Malta’s Highly Qualified Persons Programme

Malta, a charming Mediterranean island nation, has become increasingly popular among expatriates and professionals seeking to relocate to a vibrant, culturally rich, and economically stable country.

One of the key factors driving this interest is the Highly Qualified Persons Programme (HQP), introduced by the Maltese government to attract talented individuals and strengthen its economy. This programme offers a range of benefits to eligible applicants, making it an attractive option for highly qualified individuals from around the world.

What is the Criteria?

In order to be eligible for the HQP programme, you would need comply with the following rules below:

  1. Eligible Employment:  An individual must be employed in an eligible office with a company that is licensed, and/or recognised by the Competent Authority regulating the specific sector.  Qualifying roles typically include positions in fields such as; finance, gaming, aviation, and other sectors that are in high demand in Malta.
  2. Minimum Qualifications and Salary: You should possess specific qualifications and skills that are relevant to your profession. Additionally, your annual gross salary should meet a minimum threshold, which may vary depending on the specific eligibility criteria at the time of your application. As of October 2023, the minimum salary requirement is โ‚ฌ93,669 for the basis year 2023.
  3. Health Insurance: You are required to have valid health insurance that covers you and any accompanying dependents.
  4. Residential Property: HQP applicants are usually required to either purchase (only available for EU Nationals), or rent a qualifying property in Malta, which serves as their primary residence.
  5. Clean Criminal Record: Applicants and their dependents should not have any criminal convictions.
  6. Genuine Link to Malta: You should establish a genuine link to Malta, which may include having a physical presence in Malta and being an active part of the community.
  7. Application Fees: Applicants need to be prepared to pay the necessary application and processing fees when applying for the programme.

What are the Benefits?

Tax Incentives

The HQP program is well-known for its attractive tax incentives, which are among the most compelling benefits for applicants. Successful candidates can enjoy a flat tax rate of 15% on their Malta-source income, provided it meets the eligibility criteria. Income exceeding โ‚ฌ5,000,000 is exempt from income tax in Malta.

The Malta tax benefits under this scheme apply to EEA and Swiss nationals for a maximum consecutive period of 5 years, preceding the first year of assessment and to third country nationals for a maximum consecutive period of 4 years.

EEA/Swiss nationals who take advantage of this tax benefit shall be eligible, upon application, for a two-time extension of 5 years, making the qualifying period a maximum of 15 years of assessment and offering significant savings compared to other countries, with higher income tax rates.

Third country nationals may extend their programme twice by another 4 years, bringing their maximum time in Malta to 12 years.

The tax benefits make Malta particularly appealing for high-earning professionals and entrepreneurs who want to optimise their financial planning.

Diverse Business Opportunities

The HQP programme is limited to specific industries, including; Financial Services , Research & Development, Gaming, and Aviation and Oil and Gas. Malta has established itself as a hub for various industries, offering ample opportunities for entrepreneurs and skilled professionals. The Government is keen to attract foreign investment, leading to a business-friendly environment that promotes innovation and growth.

Education Opportunities

The HQP programme offers access to Malta’s high-quality education system. International schools in Malta provide an excellent education for expatriate children, often following international curricula. In addition, Malta’s two universities, the University of Malta and the Malta College of Arts, Science and Technology, offer a wide range of programmes and research opportunities, making it an excellent destination for those seeking advanced academic degrees.

Quality of Life in Malta

Malta offers an exceptional quality of life. Its pleasant Mediterranean climate, picturesque landscapes, and a rich cultural heritage, make it an ideal place to live and work. The country boasts a strong sense of community, a safe environment, and a high standard of healthcare and education. Furthermore, Malta’s strategic location makes it an excellent hub for travel and exploration of the broader European region.

Malta’s historical and cultural heritage is one of its most distinctive features. The island is home to numerous UNESCO World Heritage Sites, including the ancient city of Valletta. Its vibrant arts scene, diverse festivals, and cuisine, attracts individuals looking for a rich cultural experience. Malta’s multicultural society also welcomes people from various backgrounds, creating a dynamic and inclusive environment.

Conclusion

The Highly Qualified Persons Programme in Malta is a remarkable opportunity for highly skilled professionals and their families to move to a Mediterranean island.

With its enticing tax incentives, EU membership, diverse business opportunities, and an exceptional quality of life, Malta has become a top destination for those looking to enhance their personal and professional lives.

The programme’s inclusivity, and the rich sunny weather on offer, also make Malta an appealing choice for those seeking a new place to call home while advancing their careers and quality of life.

How Dixcart can help?

As a Licensed Residency Agent, Dixcart can assist in the submission and management of the HQP application, and ensure a smooth and steam lined process, making it as straight forward as possible.

For further information about the benefits of the HQP, please contact Jonathan Vassallo, at the Dixcart office in Malta: advice.malta@dixcart.com.

Alternatively, please speak to your usual Dixcart contact.

Dixcart Management Malta Limitedย Licence Number: AKM-DIXC.

Programmes to Move to or Become Tax Resident in Cyprus

Background

Numerous tax advantages exist in Cyprus, for companies and previously non-Cypriot resident individuals. Please see Article:ย ย Tax Efficiencies Available in Cyprus: Individuals and Corporates.

Individuals

Individuals can move to Cyprus, to take advantage of the tax efficiencies available, by spending at least 183 days in Cyprus without additional conditions.

For individuals with closer ties to Cyprus such as running/operating a business in Cyprus and/or being a director of a company which is tax resident in Cyprus, the โ€˜60 Day Tax Residency Ruleโ€™ might be of interest

1. The โ€œ60 Dayโ€ Tax Residency Ruleย 

Since the implementation of the 60-day tax residency rule, a number of individuals have relocated to Cyprus to take advantage of the various tax benefits that are available.

Criteria to Meet the โ€œ60 Dayโ€ Tax Residency Rule

The โ€œ60 dayโ€ tax residency rule applies to individuals who in the relevant tax year:

  • reside in Cyprus for at least 60 days.
  • operate/run a business in Cyprus and/or are employed in Cyprus and/or are a director of a company which is tax resident in Cyprus. Individuals must also have a residential property in Cyprus which they own or rent.
  • are not tax resident in any other country.
  • do not reside in any other single country for a period exceeding 183 days in aggregate.

Days Spent In and Out of Cyprus

For the purpose of the rule, days โ€œinโ€ and โ€œoutโ€ of Cyprus are defined as:

  • the day of departure from Cyprus counts as a day out of Cyprus.
  • the day of arrival in Cyprus counts as a day in Cyprus.
  • arrival in Cyprus and departure on the same day counts as a day in Cyprus.
  • departure from Cyprus followed by a return on the same day counts as a day out of Cyprus.

Please note that for the majority of jurisdictions you do not become tax resident if you reside there for less than 183 days a year. In certain jurisdictions, however, the number of days to be considered tax resident, is fewer than this. Professional advice should be taken.

2.ย  Starting a Business in Cyprus as a Means of Relocation for Non-EU Nationals

Cyprus is an attractive jurisdiction for trading and holding companies, with access to all EU directives and an extensive network of double tax treaties.

To encourage new business to the island, Cyprus offers two temporary visa routes as a means for individuals to live and work in Cyprus:

  • Establishing a Cyprus Foreign Investment Company (FIC)

Individuals can establish an international company which can employ non-EU nationals in Cyprus. Such a company can obtain work permits for relevant employees, and residence permits for them and their family members. A key advantage is that after seven years, non-EU nationals can apply for Cyprus Citizenship.

  • Establishment of a Small/Medium Size Innovative Enterprise (Start-up Visa)ย 

This scheme allows entrepreneurs, individuals and/or teams of people, from countries outside the EU and outside the EEA, to enter, reside and work in Cyprus. They must establish, operate, and develop a start-up business, in Cyprus. This visa is available for one year, with the option to renew for another year.

3. The Permanent Residence Permit

Individuals wishing to move to Cyprus can apply for a Permanent Residence Permit which is useful as a means to ease travel to EU countries and organise business activities in Europe.

Applicants must make an investment of at least โ‚ฌ300,000 in one of the investment categories required under the programme, and prove they have an annual income of at least 50,000 (which can be from pensions, overseas employment, interest on fixed deposits, or rental income from abroad). If the holder of a Permanent Residence Permit resides in Cyprus, this may make them eligible for Cyprus citizenship by naturalisation.

4. Digital Nomad visa: non-EU nationals who are self-employed, salaried, or working on a freelance basis can apply for the right to live and work from Cyprus remotely.

Applicants must work remotely using information technology and communicate remotely with clients and employers outside Cyprus.

A Digital Nomad has the right to stay in Cyprus for a period of up to one year, with the right to renew for another two years. During the stay in Cyprus the spouse or partner and any minor family members, cannot provide independent work or engage in any kind of employment activity in the country. If they reside in Cyprus for over 183 days in the same tax year, then they are considered to be tax residents of Cyprus.

Each digital nomad must have; a salary of at least โ‚ฌ3,500 per month, medical cover and a clean criminal record from their country of residence.

Currently the cap of the total amount of allowed applications has been reached and therefore this programme is currently unavailable.

  1. Application for Cypriot Citizenship

The option is available to apply for Cypriot citizenship after a period of five years of residence and work within the Republic of Cyprus.

Additional Information

For further information about the attractive tax regime for individuals in Cyprus, and the visa options available, please contact Katrien de Poorter at the Dixcart office in Cyprus:ย advice.cyprus@dixcart.com.