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Living in Malta from the UK

Malta's attraction for British residents is usually described in one sentence: foreign income is taxed only if you bring it in. That sentence is about Maltese law, and Maltese law is only half the arrangement. The other half is article 23 of the UK-Malta convention of 1994, which limits the relief the United Kingdom gives to the part of the income Malta actually taxes. This page quotes both, with the dates each was read.

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Malta taxes a resident who is not domiciled there on foreign income only to the extent it is remitted. That much is Maltese law, it is real, and it is why the search exists.

It is also half of the arrangement. The other half is article 23 of the UK–Malta convention of 1994, which says that where the convention relieves income from tax in one state and the other state taxes it only on what is remitted, the relief applies only to so much of the income as is taxed in the other state.

Put the two together and the shape changes: the part you do not remit is not sheltered by the treaty either. This page sets out both instruments and the residence machinery around them. Maltese routes, thresholds and the permit itself are in our Malta guide.

The UK–Malta tax treaty was signed in 1994 and modified by the MLI from 2020

The two instruments that govern a British person in Malta, on one timeline. The convention was signed on the twelfth of May 1994 and entered into force on the twenty-seventh of March 1995, taking effect in the United Kingdom from the first of April 1996 for corporation tax and the sixth of April 1996 for income tax and capital gains tax, and in Malta from the first of January 1996. The Multilateral Instrument then entered into force on the first of October 2018 for the United Kingdom and the first of April 2019 for Malta, and has effect for this convention from the first of January 2020 at source, from the first and the sixth of April 2020 in the United Kingdom, and for Maltese taxable periods beginning on or after the first of January 2020. It added a principal purpose test under article seven. It left articles four, eighteen and twenty-three of the convention unchanged.

Signed 12 May 1994. Entered into force 27 March 1995. Effective in the United Kingdom from 1 April 1996 for corporation tax and 6 April 1996 for income tax and capital gains tax, and in Malta from 1 January 1996.

The Multilateral Instrument then reached it. It entered into force on 1 October 2018 for the United Kingdom and 1 April 2019 for Malta, and has effect for this convention from 1 January 2020 at source, from 1 and 6 April 2020 in the United Kingdom, and for Maltese taxable periods beginning on or after 1 January 2020.

What the MLI changed, and what it did not. It added a principal purpose test under MLI article 7: a benefit is not granted where it is reasonable to conclude that obtaining it was one of the principal purposes of the arrangement. It left articles 4, 18 and 23 — residence, pensions and limitation of relief — as they were. The synthesised text is published on gov.uk, which is itself worth noting: for Greece, whose convention dates from 1953, no synthesised text is published at all.

One precision that will save you a wasted comparison. HMRC records that the words "Malta to a company which is a resident of" were in the convention signed on 12 May 1994 and were "inadvertently omitted from the published text" in Statutory Instrument 1995 No. 763, and that it applies article 22(1)(b) in line with the signed text. So the published version of this treaty is known to be incomplete, and the tax authority says so itself.

Article 4(2) settles dual residence in four steps, and nationality is the third

In the year of a move both countries commonly treat you as resident. The convention resolves it in a fixed order:

  1. A permanent home available to you. If one is available in both states, the state with which your personal and economic relations are closer — the centre of vital interests.
  2. Habitual abode, if the centre of vital interests cannot be determined or no home is available in either state.
  3. Nationality, if habitual abode is in both states or in neither.
  4. Agreement between the two competent authorities, if you are a national of both or of neither.

The first limb, verbatim:

> "he shall be deemed to be a resident solely of the Contracting State in which he has a permanent home available to him; if he has a permanent home available to him in both Contracting States, he shall be deemed to be a resident solely of the Contracting State with which his personal and economic relations are closer (centre of vital interests)"

"Available" is the word to read twice. A flat kept empty in Britain is available to you. And nationality, which relocation pages treat as decisive, is the third step of four.

Which country taxes a UK pension for a British resident of Malta

Article 18(1):

> "Subject to the provisions of paragraph (2) of Article 19 of this Convention, pensions and other similar remuneration paid in consideration of past employment, or any annuity paid, to a individual who is a resident of a Contracting State shall be taxable only in that State."

The wording "to a individual" is in the published text; we quote it as it stands.

The rule is the state of residence, which is the modern default and the same rule the 2025 UK–Portugal convention carries. Government service pensions are the exception, held back by article 19(2).

But article 18 does not finish the sentence for Malta, because the state of residence here is one that may tax only what arrives. That is what the next section is about.

Article 23 limits UK relief to the income actually taxed in Malta

Article twenty-three, paragraph one, of the 1994 convention drawn as a narrowing channel in three steps. First, an item of income is relieved from tax in one state under some provision of the convention. Second, in the other state that person is taxed on that income by reference to the amount remitted to or received in that state, and not by reference to the full amount. Third, the relief allowed in the first state then applies only to so much of the income as is taxed in the other state. The width of the channel at the end is set by the amount remitted, not by the amount earned.

The text, in full:

> "Where under any provision of this Convention any income is relieved from tax in a Contracting State and, under the law in force in the other Contracting State, a person, in respect of that income, is subject to tax by reference to the amount thereof which is remitted to or received in that other Contracting State and not by reference to the full amount thereof, then the relief to be allowed under this Convention in the first-mentioned Contracting State shall apply only to so much of the income as is taxed in the other Contracting State."

Read it as a mechanism. Article 18 sends a private pension to the state of residence, so the United Kingdom relieves it. Malta then taxes the remitted part. Article 23(1) shrinks the UK relief to that remitted part.

The proposition "keep it offshore and it is taxed nowhere" describes Maltese law accurately and stops one instrument short.

What we are not telling you is how HMRC applies this to any particular pension or income stream. We have read the article; we have not read a determination. The article is the thing to take to whoever does your return, and it has a number.

Article 23(2) can remove the convention entirely, and we cannot tell you when

The second paragraph:

> "The provisions of this Convention shall not apply to persons entitled to any special tax benefit under: (a) a law of either one of the Contracting States which has been identified in an Exchange of Notes between the Contracting States; or (b) any substantially similar law subsequently enacted."

Malta runs several regimes that grant a special tax status to incoming residents. Whether any of them is a law "identified in an Exchange of Notes" is a question about a document we have not read.

So we make no claim about any named programme, in either direction. What we will say is that a page recommending a Maltese special-status regime to a British person, without mentioning that the convention contains a paragraph capable of switching itself off, has left out something the reader would want to know exists.

Comparing living costs in Malta with the UK needs a measured Maltese figure

This is the most-searched British question about Malta — more searched than the move itself — and it is usually answered from listing sites.

Malta has something better, and we used it on the cost of living in Malta: the register of lease contracts. The median rent on newly signed contracts in 2023 was €850, against €1,400 to €1,500 in advertisements. Rent is the largest line in the comparison, and the two sources differ by more than half.

The other half of the comparison is where we stop. We have no equivalently measured UK figure that we have read at source, and Malta's own household expenditure survey was last run in 2015–2016. A confident two-country number would have to come from somewhere, and everywhere it could come from is a listing site.

So: the Maltese half is measured and linked, and the British half is not ours to invent.

The UK government publishes a Living in Malta page, and this is the layer it does not cover

Unusually for our subjects, a British person searching this finds their own government on the first screen: gov.uk's "Living in Malta" appears twice among the results we read on 9 September 2026.

That page is worth opening, and it is not what this one duplicates. The convention, its article numbers, the remittance limitation and the MLI dates are not the FCDO's subject.

The commercial guide alongside it is the instructive one. A relocation guide of fifteen to eighteen thousand words, last updated 2 July 2026, discusses the remittance basis at length and links to the UK–Malta convention page on gov.uk. It does not contain "1994", "Article 23" or "limitation of relief". The treaty is cited and not opened — which is a more specific failure than ignoring it.

Visa routes for British citizens moving to Malta are not on this page

Malta runs no UK-specific route. A British citizen arriving now is a third-country national and applies under the ordinary categories, which are set out with what each requires, and the date each rule was read, in our Malta guide. The nomad permit and its own tax rules are in the Malta nomad residence permit.

Citizenship is a separate subject with a recent and badly reported history: the investment route was abolished rather than suspended after the Court of Justice ruled in case C-181/23, and what remains is in Malta citizenship after the Court of Justice.

What this page does not claim about living in Malta from the UK

Your actual tax. The convention allocates and relieves; the figure depends on your own circumstances in two systems and on which Maltese status you hold.

Which Maltese laws are named in the Exchange of Notes. Not read, so not claimed.

How HMRC applies article 23(1) in practice. Not read, so not claimed. We quote the article.

Social security. Whether any UK–EU arrangement covers contributions in Malta is something we have not read, and we say nothing about it in either direction.

A UK cost-of-living figure. We have not read one at source, and we are not going to derive one from advertisements.

Frequently asked questions about living in Malta from the UK

Is there a double taxation treaty between the UK and Malta?

Yes. It was signed on 12 May 1994 and entered into force on 27 March 1995. It has been modified by the Multilateral Instrument, which has effect for it from 2020 and added a principal purpose test; a synthesised text is published on gov.uk.

Does the Maltese remittance basis mean my foreign income is untaxed?

Not as far as the treaty is concerned. Article 23(1) provides that where income is relieved from tax in one state and the other taxes it only on the amount remitted, the relief applies only to so much of the income as is taxed in that other state.

Which country taxes my UK pension if I live in Malta?

Article 18(1) makes pensions and annuities taxable only in the state of residence, subject to article 19(2) for government service pensions. Article 23(1) then governs how much relief follows if Malta taxes only what is remitted.

What happens if both the UK and Malta consider me resident?

Article 4(2) applies four steps in order: a permanent home available to you, then the centre of vital interests, then habitual abode, then nationality, then agreement between the two tax authorities.

Do British citizens need a visa to live in Malta?

Yes. A British citizen arriving now is a third-country national and applies under the ordinary Maltese categories, which are set out in our Malta guide.

Can I still get Maltese citizenship by investment as a British citizen?

No. The route was abolished, not suspended, after the Court of Justice ruled in case C-181/23; the amending act and the rewritten subsidiary legislation are named on our Malta citizenship page.

More on Maltese residence, citizenship and living costs

Routes, thresholds and the permit itself: the Malta guide. What the island costs, from the lease register rather than from listings: the cost of living in Malta. The nomad permit and its tax rules: the nomad residence permit. What was abolished and what remains: Malta citizenship after the Court of Justice. The British equivalent for three other destinations: living in Greece from the UK, moving to Portugal from the UK and moving to Dubai from the UK.

Every instrument named here has its own line, with the date it was read, on our sources page.

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