Malta Retirement Programme 2026: who can use it, the Global Residence Programme for Americans, and where an annuity fits
Written by Hans Goldstein, licensed insurance agent · CA 4273294Short answer: Malta’s Retirement Programme (S.L. 123.134) taxes foreign income remitted to Malta at a flat 15%, with a minimum of €7,500 a year plus €500 per dependent, and its rules count lifetime or temporary annuities as pension. But the status ends if the holder “becomes a third country national” (rule 6), so in practice it is for EU, EEA and Swiss citizens: an American with, say, an Italian or Irish passport. A US-only citizen uses the Global Residence Programme (S.L. 123.148), which is limited to third-country nationals: 15% on remitted foreign income, a €15,000 minimum tax, and proof of “stable and regular resources” with no fixed figure, which a lifetime annuity documents well. Both need a home bought for €275,000 (€220,000 in Gozo or the south) or rented for €9,600 a year (€8,750). Malta has no wealth tax and no inheritance tax.
Free guide: Moving abroad on a fixed income
Income rules and taxes by country: Norway, Switzerland, Sweden, Italy, Spain, Malta and more, plus how a lifetime annuity fits.
Two programmes: which one fits an American
Malta has two special tax statuses for people who move there without working. Both tax foreign income you bring into Malta at a flat 15%, both need a qualifying home, and both are applied for through an authorised registered mandatary (a Maltese lawyer, notary, accountant or similar). The difference is who can use them.
| Rule | Malta Retirement Programme (S.L. 123.134) | Global Residence Programme (S.L. 123.148) |
|---|---|---|
| Who | Not a Maltese national; status ends if the holder becomes a third-country national (rule 6(1)(b)), so EU, EEA and Swiss citizens | Third-country nationals only, not Maltese, EEA or Swiss (rule 4(a)): US-only citizens |
| Income test | A “pension” of at least 75% of chargeable income, all received in Malta | “Stable and regular resources” sufficient for you and your dependants; no fixed figure |
| Annuities | Named: “pension” includes lifetime or temporary annuities and insurance policies | Any stable, regular income; a lifetime annuity is a natural proof |
| Tax | 15% on foreign income received in Malta; minimum €7,500 a year plus €500 per dependent | 15% on foreign income received in Malta; minimum €15,000 a year |
| Application fee | €2,500 | €6,000 (€5,500 for a property in the south of Malta) |
| Home | Buy for at least €275,000 (€220,000 in Gozo or the south of Malta), or rent for at least €9,600 a year (€8,750 in Gozo or the south) | |
| Time | At least 90 days a year in Malta averaged over five years; no more than 183 days a year in any other country | No more than 183 days a year in any other country |
| Health | Sickness insurance covering all risks across the EU for you and your dependants | |
| Other | Not employed; not domiciled in Malta | Must communicate adequately in Maltese or English |
The rules are the subsidiary legislation itself, last amended by Legal Notice 69 of 2020. Both statuses are tax statuses: ask your mandatary how the residence permit itself is issued alongside them, especially as a non-EU citizen. USD figures use $1.17 per euro (a planning rate; the ECB reference rate was $1.1225 on 2 October 2026, so these dollar figures include about 4% of headroom).
Single or married: what a couple needs
Neither programme sets an income figure, so for a couple the question is how the status and the minimum tax are split. Under both, the spouse (or a partner in a stable and durable relationship) is a dependent of the beneficiary, and the spouse’s foreign income received in Malta is also taxed at 15%.
| Household | Retirement Programme minimum tax | Global Residence Programme minimum tax | Who must qualify |
|---|---|---|---|
| Single | €7,500 (about $8,775) | €15,000 (about $17,550) | The beneficiary |
| Couple, spouse as dependent | €8,000 (about $9,360) | €15,000 (the minimum covers the household’s foreign income) | The beneficiary; under the MRP the 75% pension test is on the beneficiary’s own income |
| Each child | +€500 | No separate amount in the rules | The beneficiary |
Spouses may hold the same qualifying property jointly, and dependents must live with the beneficiary in it.
When only one spouse has the income
Make the spouse with the income the beneficiary and the other a dependent. Under the Retirement Programme that matters most, because the 75% pension test is measured on the beneficiary’s own chargeable income. If more pension income is needed, put the lifetime annuity in the beneficiary’s name: that spouse owns the contract and receives the payments, it is priced on that spouse’s age and sex, and it must be bought while you both still live in the US. In a mixed couple where only one spouse holds an EU passport, ask a Maltese adviser which programme fits before you buy anything.
Funding it from the other spouse’s money is a gift between spouses. General information, confirm with a tax adviser: gifts between two US-citizen spouses are unlimited; gifts to a spouse who is not a US citizen are excluded from taxable gifts up to $194,000 in 2026 (IRC 2523(i)), and above that you file Form 709, usually with no tax due.
Where an annuity fits
Retirement Programme (EU passport holders). Many regimes leave you arguing about whether a private annuity is a “pension.” The MRP rules settle it: lifetime or temporary annuities and insurance policies count, and lump sums and commuted capital do not. A life-only single premium immediate annuity (SPIA) from a US insurer can lift your pension share above the 75% line if most of your other money produces dividends or interest.
Global Residence Programme (US-only citizens). There is no pension test, so an annuity is not required. Its job is to document “stable and regular resources” with a monthly amount paid for life, which is easier to show year after year than a brokerage balance.
Which annuity counts
Under the MRP the rules name “lifetime or temporary annuities”, so a period-certain annuity can count as pension, as can a life-only or joint and survivor SPIA, or an existing deferred annuity or MYGA converted to payments. What does not count: a lump sum, commuted capital, or an annuity still accumulating, because nothing is being paid out. A temporary annuity ends, and the status needs the 75% test met every year, so a lifetime payout is the safer fit. Buy it while you still live in the US; US insurers generally will not issue to someone already living abroad.
Why I write about this. My mom is Norwegian, my dad is American, and they’re planning the move from the US to Norway. My mom is the sponsor (the host, or “reference person” in UDI’s words), so Norway’s income test falls on her income, not my dad’s. UDI told us in writing that money in an account does not count as income, and only lifelong income does. Their savings were not the problem; the paperwork wanted a monthly number in the host’s name. The rules in Malta are different, but the problem is the same one many retirees hit: the income test, not the net worth. I’m writing this to help others in the same boat as my parents. Read how we worked through the Norway income requirement.
In the same boat? Let’s run your numbers
See roughly what a lifetime annuity would cost to close your income gap, then get my personal read by email. I can help while you still live in the US.
Estimates use the September 9, 2026 ImmediateAnnuities.com payout survey (life only) and a 15% cushion. Illustrative, not a quote.
The real bar: the minimum tax and the property
Because neither programme has an income figure, think about it the other way around. The MRP’s €7,500 minimum is 15% of €50,000, and the GRP’s €15,000 minimum is 15% of €100,000. Below those levels of remitted income you still pay the minimum, which is not refundable. Add the property or rent requirement and health cover. This is a route for people with real assets, not a budget move.
Example: a 62-year-old American moving to Malta
Premium = monthly target / payout per $100,000 x $100,000. At 62 the ImmediateAnnuities.com survey of September 9, 2026 (life-only, per $100,000 a month) averages $603 for a man and $582 for a woman; the best quotes were $660 and $637. Rounded to the nearest $1,000. Illustrative, not a quote.
| Household, age 62 | Monthly income added | Premium, average rate | Premium, best rate |
|---|---|---|---|
| Single man, top-up of lifetime income | $1,500 | $249,000 | $227,000 |
| Single woman, same top-up | $1,500 | $258,000 | $235,000 |
| MRP, single man, no other pension: €50,000 a year (where 15% equals the €7,500 minimum) | $4,875 | $808,000 | $739,000 |
| Couple: annuity on the beneficiary only (he is 62) | $1,500 | $249,000 | $227,000 |
Social Security can start at 62 and counts as pension for the MRP. For a couple, a joint and survivor annuity keeps paying after the first death but pays less per dollar than single life; get a quote for both. Under MRP rule 3(3), if the beneficiary dies, the status can pass to a dependent who inherits or rents the qualifying home and meets the other conditions.
How the annuity is taxed: Malta and the US
The Maltese side. Under either programme, foreign income received in Malta by the beneficiary and spouse is taxed at a flat 15%, subject to the minimum tax, with double tax relief available under the Income Tax Act. Under the MRP all of the pension must be received in Malta; other income of a beneficiary that does not fall under the 15% rule is taxed at 35%. Whether any capital element of a purchased annuity payment is excluded in Malta is not spelled out in the programme rules, so ask your Maltese adviser.
The treaty. Under the US-Malta income tax treaty, annuities paid to a resident of Malta are taxable only in Malta (Art. 17(3)). The saving clause (Art. 1(4)) lets the US tax its citizens anyway, and under Art. 23(4) Malta gives no credit for US tax charged only because of citizenship, while the US credits the Maltese tax and treats the annuity income as arising in Malta so the credit works. US Social Security paid to a Malta resident is taxable only in the US (Art. 17(2)).
The US side. As a US citizen you stay taxable on worldwide income wherever you live. A US single premium immediate annuity bought with after-tax savings is taxed under IRC 72: an exclusion ratio makes part of each payment a non-taxable return of your premium until the premium is recovered. If you bought it with IRA money, every payment is taxable. The foreign earned income exclusion does not cover annuities (IRC 911(b)(1)(B)(i)). Foreign tax on the payments can be credited on Form 1116 (passive category income), through the treaty’s relief article where there is one; claiming the treaty re-sourcing rule may also call for Form 8833. Since January 1, 2026, a US citizen with a foreign residence address cannot opt out of federal withholding, even if payments go to a US account (IRC 3405(e)(13), Treas. Reg. 31.3405(e)-1). Withholding is a prepayment, not extra tax. An annuity from a US insurer is not reported on FBAR or Form 8938, and it is not a PFIC.
Net result. At low and middle income levels the minimum tax is usually the binding cost, not the rate: €7,500 or €15,000 a year whatever you remit. Above those levels, 15% of the remitted annuity is often close to or above the US tax on its taxable part, so Malta tends to be the binding tax. The annuity is roughly neutral against drawing down savings, since both are taxed at 15% when brought into Malta.
Do not confuse Malta residence with a “Malta pension plan”. Some promoters sold Maltese retirement schemes as a way to move US retirement money untaxed under the treaty. The US and Malta narrowed that in 2021 and the IRS has treated these schemes as abusive. Living in Malta is fine; buying a Maltese pension scheme to dodge US tax is not.
Does Malta have a wealth tax?
No. PwC’s Worldwide Tax Summaries (reviewed September 30, 2026) state there are no net wealth taxes in Malta and no inheritance, estate or gift taxes, though stamp duty applies to transfers of Maltese property. So the annuity is not a wealth tax play here; it is a clean way to show income the rules accept.
The trade-offs, once
A SPIA is irrevocable, level unless you add a cost-of-living rider, paid in dollars, and backed by the issuing insurer’s claims-paying ability. Malta’s minimum tax applies whether or not your income is high, so run the numbers before choosing either programme.
Married? Make the income outlive either of you. In Malta the main applicant shows the income and the spouse joins as a family member, so the annuity sits with the main applicant. If a single-life annuity is on one spouse and that spouse dies first, the payments stop, and the surviving spouse may have to show income of their own at the next renewal. A joint and survivor annuity, which keeps paying until the second death, or a separate annuity on each spouse closes that gap. Joint and survivor pays less per dollar than single life, so ask for both quotes and compare.
Frequently asked questions
Free annuity gap analysis for Malta. Tell me your ages, your Social Security or pension, and whether you are single or a couple. I will show how far your income is from the Malta requirement and what a lifetime annuity would cost to fill the gap, in the sponsor’s or main applicant’s name where that matters.
Related reading
- Retire abroad: income requirements by country
- Italy elective residence visa
- Spain non-lucrative visa
- Wealth tax countries and annuities
- How European countries tax a US annuity
- FBAR, FATCA and double taxation
Sources
- Malta S.L. 123.134: Malta Retirement Programme Rules
- Malta S.L. 123.148: Global Residence Programme Rules
- PwC Worldwide Tax Summaries: Malta, other taxes
- US-Malta income tax treaty (US Treasury text)
- IRS: 2026 inflation adjustments (gift exclusion for a non-citizen spouse)
- 26 U.S.C. 72 (annuities, exclusion ratio)
- 26 U.S.C. 911 (foreign earned income exclusion; annuities excluded)
- 26 U.S.C. 3405 (withholding on pensions and annuities)
- 26 CFR 31.3405(e)-1 (withholding on payments to US citizens with a foreign address, from 2026)
- IRS: Comparison of Form 8938 and FBAR requirements
- ImmediateAnnuities.com: immediate annuity rates by age (survey of September 9, 2026)
Goldstein & Co. LLC dba Goldstein Insurance Services · Hans Goldstein, licensed insurance agent, CA lic. #4273294 · NPN 20602398 · 213-414-2808 · hans@hansgoldstein.com
Education, not tax, legal or immigration advice. Rules, thresholds and exchange rates change; confirm with the consulate or immigration authority and a local tax adviser before you act, and get answers in writing. Hans Goldstein is a licensed insurance agent (CA 4273294) and can only offer annuities to residents of states where he is licensed. Annuity payments are guaranteed by the issuing insurer’s claims-paying ability, not by any government. Payout figures are illustrations from a published survey, not quotes. Immediate annuities are generally irrevocable.