Kehrtwende bei Krypto-Besteuerung in Deutschland in Sicht
September 10, 2026
Strategic realignment of your center of vital interests.
Relocating to Malta is more than a change of address—it is a strategic legal repositioning. We guide you in selecting the optimal residency status and set the stage for your global mobility.
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Legally Compliant Departure (The Exit Strategy)
Advisory on the avoidance or mitigation of exit taxation. Documentation of the surrender of habitual residence in the country of departure. Strategic guidance on terminating unlimited tax liability.
2. Strategic Residency Decisions (The Entry)
Ordinary Residence: Self-sufficient, Self-employed, Employed. Or: The Residence Programme (TRP), specialized solutions for EU nationals. High Net Worth Individual (HNWI) status: tailored concepts for exclusive requirements. Nomad Residence Permits: legal certainty for location-independent entrepreneurs.
3. Private Compliance & Integration (Centre of Vital Interests)
Assistance with obtaining the Tax ID and the Maltese identity card (e-Residence). Advisory on the "economic substance" of private life (lease agreements, local integration). Guidance on onboarding family members to private bank accounts.
1. Why is Malta the ideal destination for High-Net-Worth Individuals, entrepreneurs, and digital nomads?
Answer: Malta combines an exceptional quality of life in the Mediterranean EU with an outstanding English-speaking infrastructure and a stable legal framework. Furthermore, Malta offers short flight connections to key European hubs. Entrepreneurs and high-net-worth individuals benefit from this first-class international connectivity, high personal safety, and the Remittance Basis Tax System attractive remittance basis of taxation for Non-Doms, which leaves foreign capital gains completely tax-exempt and taxes foreign-source income only if remitted to Malta.
2. What distinguishes the status of "Ordinary Residence" from the "Non-Domiciled" (Non-Dom) status?
Answer:
Ordinary Residence: Refers to your actual physical and tax residence. Anyone who spends more than 183 days a year in Malta or firmly establishes their centre of vital interests there becomes a tax resident.
Non-Domiciled (Non-Dom): Describes your legal domicile (Domicile of Origin). Since you retain your domicile of origin as an expatriate, you fall under Malta's remittance basis of taxation. Foreign-source income is only subject to tax if it is remitted to Malta (remitted); foreign capital gains (Capital Gains) remain completely tax-exempt, even if remitted to Malta.
3. Which special residency and tax programmes does Malta offer for expatriates?
Answer: Depending on your nationality and wealth structure, several tailored programmes are available:
The Residence Programme (TRP) / Global Residence Programme (GRP): For EU or non-EU nationals, offering a flat tax rate of 15 % 15% on foreign-source income remitted to Malta (subject to an annual minimum tax of €15,000).
Malta Permanent Residence Programs (MPR/MPRP): For third-country nationals seeking permanent residency in Malta and visa-free access across the Schengen Area through qualifying investment and property criteria.
Nomad Residence Permit: Specifically designed for location-independent employees, freelancers, or entrepreneurs from outside the EU seeking to work remotely from Malta on a temporary basis.
4. Does relocating to Malta automatically protect against tax liability in your home country?
Answer: No. The physical relocation must be executed in a legally watertight manner to avoid double taxation or the accusation of a sham departure. Particularly for departures from Germany, critical matters such as Exit Tax (Section 6 of the German Foreign Tax Act / AStG) regarding corporate shareholdings, as well as the five-year extended tax liability period under German inheritance and gift tax rules, must be resolved proactively. Our law firm structures your departure to ensure complete legal certainty and tax compliance.
5. How does bank account onboarding and the application for local e-ID cards work in Malta?
Answer: Following the relocation of your residence, we register you with the Maltese identity agency (Identità) to obtain the e-ID Card (Schengen residence permit / e-Residence card). In parallel, we prepare the onboarding process with local Maltese banks or European Electronic Money Institutions (EMIs). Through our law firm's structured preparation of your Source of Wealth and Source of Funds documentation (Source of Funds / Wealth) we ensure a smooth, efficient onboarding process without months of compliance delays.
6. How does the law firm support the entire relocation process?
Answer: We offer a comprehensive, single-source full-service package:
Preliminary analysis: Legal and tax assessment of departure criteria in the country of origin.
Programme selection: Identification of the optimal residency and tax status (such as SFO, GRP, TRP, or standard MBR/ordinary residence).
Administrative and real estate services: Review of lease or purchase agreements according to MRA/Identità specifications, alongside the full coordination of all administrative appointments in Malta.
Banking & Compliance: Legal support and management of personal and corporate bank account openings.
While many service providers focus solely on obtaining the Maltese ID card, our work begins in your home country. A residency in Malta only unfolds its full protective effect if it withstands the rigorous scrutiny of the tax authorities in your country of origin. At Kresse Law, we ensure that your new centre of vital interests does not merely exist on paper, but is recognized both legally and factually as your genuine primary residence.
We support you in Relocation & Global Mobility through legally robust planning, precise implementation, and dedicated personal assistance on the ground in Malta.
