Maltese taxation is based on domicile and residence – but not citizenship.
Domicile of choice is not acquired through citizenship, but on the demonstrated fact that the person intends to continue to reside in Malta for the rest of his/her life, and the cancellation of all connections with the domicile of birth.
Residence, on the other hand, is established by fact i.e. the intention to reside in Malta for not less than 183 days in any calendar year.
This distinction is important since, whereas a DOMICILED person is taxable on world wide income whether of capital or income nature, a resident person is taxed on INCOME REMITTED to Malta only. Capital gains earned overseas, whether remitted to Malta or not, are not taxable in Malta.
A non-resident of Malta (whether holding a Malta citizenship or not) is only taxable in Malta on INCOME ARISING (including that of capital nature ) in Malta.