The recent publication of the Tax Treatment of Highly Skilled Individuals Rules, 2026, marked the last piece of the puzzle, so to say, put in place by Malta in relation to its eco system targeting Single Family Offices.
Malta is not new to the concept of family offices. Its legislative framework has long catered for the setting up of family offices, or for particular elements of a family office framework such as an investment manager, or an SPV used to hold/invest particular asset classes in an efficient manner.
What is new is, because of some recent amendments to the local legislative framework, an eco system within our laws that now specifically caters for the needs of Single Family Offices and, therefore, of the UHNW families concerned and of the individuals actually running their family office.
Malta brings a lot to the table as far as family offices are concerned, namely a stable and transparent legal and regulatory environment, a skilled English-speaking professional community and workforce, in addition to its strategic location within Europe as an EU Member State. The legal and regulatory framework post amendments adds an important component to the mix, being specifically geared at facilitating the establishment and operation of these Single Family Offices.
One element of the local offering is the Notified Professional Investor Fund (a “NPIF”), a category of investment fund that is not subject to licensing but a notification process that the Malta Financial Services Authority is required by law to complete within 10 working days. NPIFs are particularly suited to Single Family Offices as the law also caters for such fund to be managed by an investment manager, also set up within the Single Family Office structure, that shall be exempt from licensing by the Malta Financial Services Authority where the NPIF is set up with a minimum investment of €5 million (subject to certain other statutory conditions).
Naturally, the family maintains full flexibility as to the asset classes it may wish to invest in - no restrictions there, and the local framework also caters for sub-funds to be set up, possibly each targeting a specific asset class and relative investment strategy. One may also consider other vehicles catered for locally that can bring value to a particular family office structure, including trusts, foundations, companies, amongst others - these are complemented by an attractive tax regime that brings considerable additional value to the local proposition.
When a family trust, administered by a local trustee (registered with the Malta Financial Services Authority) is established to invest in a NPIF overseen by an exempt manager, the definition of “family member/family dependent” within the regulatory framework applicable to trustees of family trusts may be extended to also include “family clients”. This results in a framework that in practice caters for the adoption of a more comprehensive approach to managing family wealth through integrated structures, by widening the concept of “beneficiaries” to include individuals who may not traditionally be deemed as such (e.g. key employees and family non-profit or charitable organisations).
The Tax Treatment of Highly Skilled Individuals Rules, 2026, consolidate and replace several special tax programmes previously in place for eligible qualified expatriates across a number of industries. These new Rules introduce a harmonised framework for the taxation of employment income (including benefits) derived by qualifying beneficiaries in eligible roles at the reduced flat rate of income tax of 15%, with the list of ‘eligible offices’ including senior posts within family offices structures for employees based in Malta.
