The minimum basic gross salary requirement shall be increased by €10,000 every five years. To this end, from basis year 2031 (i.e. 5 years after the Rules came into force) the minimum basic gross salary threshold will be €75,000, and subsequently increased to €85,000 from basis year 2036.

The Guidelines also clarify the minimum level of employment income that must be derived from a qualifying contract of employment for eligible offices listed under the Qualifying Employment in Aviation (Personal Tax) Rules (S.L. 123.168). A minimum income threshold of €45,000 shall apply for the first year of employment, with higher minimum income requirements applicable from the second year onwards.

The minimum income requirement shall be adjusted on a pro-rata basis where:

1. a qualifying contract of employment commences during part of a calendar year; or
2. a beneficiary ceases to qualify under the Rules during a particular year.

Beneficiaries of the Rules are required to submit an annual declaration to the Competent Authorities for each year of assessment in which the flat 15% tax rate is applied.

The Guidelines confirm that renewal applications are required to be submitted during the year immediately preceding the five‑year qualifying period and by no later than the end of the ninth month of that year.

Applications submitted under the Highly Qualified Persons Rules (S.L 123.126) during calendar year 2025, in respect of which no determination had been issued by 31 December 2025, will be treated as applications under the new Rules, provided that all required documentation and information had already been submitted to the respective Competent Authorities.

The Guidelines also include a detailed description of the activities carried out by eligible offices falling under the remit of the Competent Authorities, as well as a comprehensive list of information that must be included in each application submitted under the Rules.