Malta's schemes for high net worth individuals in the global market, a comparative appraisal

Abstract

The aim of this thesis is to analyse the recent introduction of the schemes directed at High Net Worth Individuals in a historical and foreign jurisdictional context. High Net Worth Individuals were always of great interest to states since they had the potential to generate large amounts of tax revenue and investment in the respective economies. The first chapter contains a historical perspective of previously enacted schemes. The study shows that traditionally Malta as always benefitted from affluent individuals. The thesis will analyse the 'six penny regime' and the reasons for its abrogation. It will then also analyse subsequent schemes enacted after the 'six penny regime' till the 'resident scheme regulations'. In the second chapter the thesis outlines the problems with the 'residence scheme regulations' and critically analyse the reasons for the need of the new High Net Worth Individuals rules. The thesis carries out an analysis of practical and legal issues that may arise with the applicability of the new schemes. The thesis separately discusses the concept of ordinary residence since it creates another option for High Net Worth Individuals. In the third chapter there is an examination of some products created by foreign jurisdictions that cater for the taxation and attraction of High Net Worth Individuals. The method of acquisition of tax residence and subsequent taxation varies from one jurisdiction to another. The thesis conducts a study of the taxation of affluent individuals by Switzerland, Jersey, Gibraltar, Hong Kong and the UK. In the fourth chapter there is a critical analysis of the High New Worth Individual rules and a consideration on the way forward. Thereafter author puts forth a number of recommendations and observations.