The new Rules consolidate and replace the following tax regimes (“Old Rules”):
- Highly qualified Persons Rules
- Qualifying Employment in Innovation and Creativity (Personal Tax) Rules
- Qualifying Employment in Aviation (Personal Tax) Rules
- Qualifying Employment in Maritime Activities and the Servicing of Offshore Oil and Gas Industry Activities (Personal Tax) Rules
- Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules
The Rules provide a preferential flat tax rate of 15% on qualifying employment income earned by eligible individuals engaged in regulated sectors.
The Rules set out eligibility criteria for new applications whilst also providing transitional provisions for eligible individuals who, as at 31 December 2025 qualified as beneficiaries under the Old Rules.
The below guide provides an overview of these new Rules.
