Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules

On 17 October 2025, Legal Notice 250 of 2025 introduced The Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules, 2025. Effective from 1 January 2025, these rules allow qualifying senior employees in family offices, back-office, and treasury management operations to benefit from a reduced 15% tax rate under Article 56(21) of the Income Tax Act.

To qualify for this tax incentive, income must arise from a contract of employment that meets the requirements set out in these Rules. The income, received by the beneficiary, must be taxable under Article 4(1)(b) of the Income Tax Act, excluding the annual value of any fringe benefits. It must reach a minimum of €65,000 per year and be derived from an eligible office. This minimum threshold will increase by €10,000 every five years, starting from the year following the entry into force of these Rules. The reduced tax rate applies to emoluments up to €7,000,000, while any income above this limit will be treated as remaining income and taxed at the standard rates that would have applied had the election not been made.

A beneficiary is an individual who satisfies the following conditions:

(a) The individual derives income subject to tax under Article 4(1)(b) of the Income Tax Act, consisting of emoluments payable under a qualifying contract of employment, received in respect of work or duties carried out in Malta, or in relation to any period spent outside Malta connected to such work or duties, including periods of leave during the performance of such work or duties.

(b) The individual’s first employment in Malta is in an eligible office under a contract of employment requiring the performance of duties in Malta, provided that the individual has not received income referred to in Articles 4(1)(a) or (b) of the Act prior to 1 January 2025.

(c) The individual is protected as an employee under Maltese law, irrespective of the legal form of the relationship with the employer, for the purpose of performing genuine and effective work for, or under the direction of, another party, is remunerated accordingly, and possesses the required adequate and specific competence, as verified by the competent authority.

(d) The individual holds the professional qualifications required for the role, as proven to the satisfaction of the competent authority.

(e) The individual is not an individual who has benefited under Article 6 of the Act.

(f) The individual fully discloses, for tax purposes, all emoluments received under a qualifying contract of employment, as well as any income from a person related to the employer in respect of activities substantially derived from such employment, which are chargeable to tax in Malta.

(g) The individual demonstrates, to the satisfaction of the competent authority, that activities of an eligible office are performed.

(h) The individual proves, to the satisfaction of the competent authority, that:

1. Stable and regular resources are received, sufficient to maintain the individual and their family in Malta without recourse to the Maltese social assistance system.
2. The individual resides in accommodation regarded as normal in Malta for themselves, and, if applicable, for their family, which meets the general health and safety standards in force in Malta. 
3. A valid travel document is held. 
4. Private medical insurance is held covering all risks normally insured for Maltese nationals, for the individual and their family, regardless of who bears the cost.
5. The individual is not domiciled in Malta.

(i) The individual meets any additional conditions deemed appropriate by the competent authority, including requirements related to training personnel in the field of expertise relevant to the eligible office held.

List of Eligible Offices:

1. Head of the Back Office and/or Chief Executive Officer, General Manager, Country Head, Managing Director, or equivalent designation.
2. Chief and/or Head Risk Officer.
3. Chief and/or Head Compliance and Anti-Money Laundering Officer.
4. Chief and/or Head Risk Officer, including Fraud and Investigations Officer.
5. Portfolio Manager.
6. Chief and/or Head Investment Officer.
7. Senior Trader.
8. Senior Structuring Professional.

Eligible Office Contexts:

1. Single-Family Offices:

1. Fund managers established in Malta exempt from the requirement for an investment services licence under Regulation 3(1)(f) of the Investment Services Act (Exemption) Regulations, provided the Notified PIF they manage is a family office vehicle investing private wealth without raising external capital.
2. Fund managers established in Malta exempt under Regulation 3(1)(t) of the Investment Services Act (Exemption) Regulations, under the same conditions.
3. Registered trustees investing, on behalf of a family trust, in a Notified PIF managed by a fund manager exempt under 3(1)(f) or 3(1)(t), provided the PIF invests private wealth without raising external capital.
4. Licence holders investing private wealth of investors without raising external capital; for these purposes, “licence holder” also includes Notified PIFs.

2. Multi-Family Offices: Licence holders investing private wealth of investors without raising external capital.

3. Back Office Services: Undertakings providing back-office services to the entities referred to in (1) or (2), confirmed in writing by the competent authority for these Rules.

4. Treasury Management Operations: Undertakings carrying out treasury management operations for the entities referred to in (1) or (2), confirmed in writing by the competent authority for these Rules.

An application for a formal determination of eligibility under these Rules and Article 56(21) of the Act must be submitted in the form or manner required by the competent authority, in agreement with the Commissioner, and include all requested information and supporting documents.