Obtaining Maltese citizenship as a result of applying under the Malta Individual Investor Program (MIIP) doesn’t automatically result in you becoming tax resident in Malta. During the first 12 months there is a requirement for an individual to be a resident of Malta prior to the issuance of the citizenship. The term "residence" here doesn’t necessarily mean "tax residence"; it means that the individual is expected to create genuine links with Malta, one of which could be tax residence. From a Maltese perspective, you will be considered a tax resident in Malta either if you spend more than 183 days here or if you register as such. Therefore, if you spend one whole year in Malta and leave the country the following year, then yes, you would be deemed to be tax resident in year one and possibly non-resident in year two.
