Tax rules for Highly Skilled Individuals

The Tax Treatment of Highly Skilled Individuals Rules, 2026 were published by LN 20 of 2026.

The rules, which enter into force with effect from 1 January 2026, consolidate the rules applying to beneficiaries under other legislation regulating the taxation of individuals in certain sectors (including the Highly Qualified Persons rules and the Qualifying Employment in Innovation and Creativity Rules and others) into a single framework.

The rules set out the criteria for eligibility to exercise the option under article 56(21) of the Income Tax Act for emoluments paid under a qualifying contract of employment to be taxed at the rate of 15%, and provide a transition period after which all applications can no longer be made under the previously applicable legislation.