Good day everyone,
I have been following Malta PR and OR schemes for some time and have had discussions with real users of the schemes. I am no expert on the subject, but I know the basics. I have been eagerly awating the new High Net Worth Individuals scheme and as I suspected, it is rather unattractive, especially for EU citizens. Introduction of this new scheme begs for several questions/observations:
1. Why would EU citizens want to go for this scheme, especially if their income arises outside of Malta? Ordinary Residence appears to be better choice, unless one remits very large amounts of money into Malta and HNWI's 15% becomes better option mathematically. I would think that HNWI is now almost exlusively attractive to non-EU citizens only.
2. I would think that HNWI makes OR look very appealing. No taxation of income that arises outside of Malta (that is not remitted into the country) is quite a good deal. This makes me a bit nervous that Malta will eventually (soon?) amend OR scheme and trim its benefits (specifically tax exemption of foreign sourced non-remitted income). Malta taxes on worldwide basis only on persons both resident and domiciled in Malta (whereas us expats are non-domiciled in Malta and thus different rules apply). This gives non-domiciled a tremendous tax edge over the domiciled, that is if one's income is derived outside of Malta.
Anyone has any insider information or valid reason to believe that OR will change in the near future? Such impuls could possibly come from Brussels, especially in light of what has been happening in Europe lately, i.e. gradual loss of sovereignty and push for "harmonisation" of tax regimes.
Thank you in advance for your feedback!
Petr