Resilience Group
Home Who We Serve What We Do Vehicles we form & manage Company Formation & Administration Trusts Foundations Fund administration Fund Administration Governance, compliance & finance Corporate Directors Nominee Shareholders Accounting & Tax Compliance & AML Specialist services Banking & Payments Re-domiciliation Reinstatements Yacht Registration Residency & Relocation Why Gibraltar Insights About Contact

Residency

Gibraltar residency: Category 2, HEPSS & ordinary residence.

Gibraltar offers three principal routes to residence. Category 2 is the high-net-worth regime, capping personal tax on the first £118,000 of assessable income. HEPSS is for senior executives with specialist skills earning over £160,000 a year in Gibraltar. Ordinary residence covers employed and self-employed applicants under the criteria published on 17 June 2026. Category 2 and HEPSS certificates are tax-status documents — they are not residence permits; immigration registration is handled separately by the Department of Immigration and Home Affairs. We coordinate applications alongside the applicant's existing legal and tax advisers and assist with relocation.

Recent changes you should know about. On 18 June 2026 the Government materially reformed Category 2: the net-worth threshold for new applicants rose to over £5 million and the application fee rose to £5,000. Separately, since 6 October 2025 Gibraltar has temporarily suspended new residency applications by UK, EEA and Swiss nationals under the Immigration (EU Exit) Regulations 2025, with narrow discretionary exceptions for genuine economic contributors approved by the Chief Minister. New ordinary-residence criteria — salary, age and accommodation tests — were published on 17 June 2026. Anyone acting now should plan around all three developments; confirm exact figures with an adviser before relying on them.

Category 2 · What it is

A capped personal-tax regime, not a tax shelter.

Category 2 status was introduced under the Qualifying (Category 2) Individuals Rules and has been a stable part of Gibraltar's personal tax framework since 1992. It grants a Gibraltar income tax certificate that limits the assessable income on which Gibraltar tax is charged to the first £118,000 per year, at standard graduated rates — producing an annual liability of approximately £37,000 as the minimum, rising to a current practical maximum of around £42,380.

Income arising outside Gibraltar — investment income, business interests, intellectual property, royalty streams, capital realised on overseas assets — is not assessed in Gibraltar above the cap. There is no Gibraltar capital gains tax, no inheritance tax, no wealth tax, and no VAT.

Category 2 is not a passport, not a residence-by-investment programme in the Maltese or Caribbean style, and not a vehicle for individuals who intend to operate a business locally — Cat 2 holders may not, as a condition of the status, engage in trade, business, or employment in Gibraltar except in narrowly defined circumstances.

It is, in practice, the regime relied on by HNWIs whose income is internationally diversified, who need a credible OECD-aligned tax base in a common-law jurisdiction within easy reach of London, and who are willing to commit to genuine residence in Gibraltar — not a paper presence.

A Category 2 certificate is a tax-status document, not a residence permit. Immigration registration is a separate step handled by the Department of Immigration and Home Affairs.

Category 2 · Eligibility

Who qualifies.

The Government of Gibraltar publishes the qualifying criteria; the load-bearing requirements are net worth, prior non-residence, available residential property, and the absence of Gibraltar business activity.

Net worth

Over £5 million

Following the changes announced on 18 June 2026, a new applicant must demonstrate an estimated total net worth in excess of £5 million, evidenced during the application. Existing Category 2 individuals are fully grandfathered and are not affected by the increased threshold, which previously stood at £2 million.

Prior residence

Not resident in the past 5 years

Applicants must not have been resident in Gibraltar during the five years immediately preceding the year of assessment. Previous residency is measured as 183 days in any tax year during those 5 years, or an average of 90 days in any three of the previous 5 years.

Property

Approved Gibraltar property

Suitable residential property in Gibraltar must be available to the applicant exclusively — either owned outright or held under a residential tenancy. The property must be of a standard appropriate to a Cat 2 holder; the Finance Centre maintains a list of approved developments.

No local business

No trade or employment in Gibraltar

Cat 2 holders may not engage in trade, business, or gainful occupation in Gibraltar except in narrowly defined circumstances and only with prior consent of the Finance Centre. Investing in or directing a Gibraltar entity that operates internationally is generally permitted; operating a local business is not.

Category 2 · Tax structure

How the calculation works.

The Cat 2 tax calculation is governed by the Qualifying (Category 2) Individuals Rules and the Income Tax Act. Resilience does not advise on the individual tax position itself — the figures below are the published structure, current as of the 18 June 2026 reforms.

Component Treatment Indicative amount
Assessable income cap Only the first £118,000 of worldwide taxable income is assessed in Gibraltar (2025/26), at standard graduated personal rates. £118,000
Minimum annual tax The practical floor charged on the assessable band — approximately £37,000, or £3,083.33 for each complete or part month the certificate is in force. ≈ £37,000
Maximum annual tax The current practical ceiling under Government of Gibraltar published schedules. ≈ £42,380
Income above the cap Worldwide income above the £118,000 band falls outside Gibraltar's charge to tax — regardless of source or amount. Not assessed
Application fee Non-refundable, following the 18 June 2026 changes (previously around £1,233). £5,000
Refundable deposit Payable on application and refunded when the status is relinquished — distinct from the annual tax. £42,380

Figures current as of the 18 June 2026 reforms and stated conservatively for orientation. Confirm exact amounts with an adviser before relying on them; the authoritative source is the Government of Gibraltar Income Tax Office and the Qualifying (Category 2) Individuals Rules as published by the Government of Gibraltar. Cat 2 figures have been adjusted periodically and may change with future Budgets.

Category 2 · Timeline

A realistic 10–14 week process.

A straightforward application — with documentation in order and property identified — typically lands a Cat 2 certificate within 10–14 weeks of starting. Complex source-of-wealth, contested UK residency exits, or property constraints can extend this. We say so up front rather than promising acceleration we cannot deliver.

01

Eligibility review

Weeks 1–2

A confidential pre-application assessment covering net worth, source of wealth, residency intent, and the applicant's current tax residency. The aim is to surface any issues — UK statutory residence test problems, source-of-wealth gaps, structural conflicts — before the application begins, when fixing them is cheap.

We work with the applicant's existing tax and legal advisers throughout; we are not a substitute for independent tax counsel.

02

Property identification & contracts

Weeks 3–7 (parallel)

Approved residential property must be identified and contracted — either purchase or residential tenancy — before the application is submitted. Property is typically the longest single-item lead time, particularly for purchase transactions where conveyancing, mortgage arrangements, and due diligence run in parallel.

We coordinate with the applicant's chosen estate agent, conveyancer, and (if applicable) Gibraltar mortgage broker. We do not act as estate agent and do not take property commissions.

03

Application & supporting documents

Weeks 5–7

The application pack is assembled: passport-level identity documents, source-of-wealth evidence (with audited financial statements, sale agreements, or other documentary support as appropriate), professional references, CV, certified property tenure documents, and the formal application form. Each document is reviewed by Resilience before submission to the Finance Centre.

For UK-domiciled applicants, this is also the moment to confirm with UK tax counsel that the statutory residence test exit is being properly evidenced. Cat 2 status alone does not end UK tax residency.

04

Government review

Weeks 8–12

The Finance Centre conducts its own due diligence on the applicant, reviews source-of-wealth documentation, and may raise queries directly with Resilience as introducer. Standard processing for a clean application is three to five weeks; complex cases run longer. We manage correspondence and respond to government queries on the applicant's behalf.

We do not lobby or otherwise attempt to accelerate Government timelines. The Finance Centre's review schedule is what it is.

05

Certificate issued & relocation

Weeks 12–14

Cat 2 certificate issued by the Finance Minister; the first year of Gibraltar tax residency commences. Resilience assists with registration at the Income Tax Office, introductions to local banking, professional service providers, schools, and (where relevant) the local family office community.

Annual filings, certificate maintenance, and ongoing residence-evidence support are continuing services Resilience offers to Cat 2 holders.

HEPSS

High Executive Possessing Specialist Skills.

HEPSS is Gibraltar's tax-status regime for senior executives whose skills are of particular economic value to Gibraltar and are not readily available locally. Like Category 2, it is a tax-status certificate rather than a residence permit.

To qualify, the applicant must occupy a senior executive position and earn more than £160,000 per annum in Gibraltar. They must also have exclusive use of approved residential accommodation in Gibraltar for the entire year of assessment.

Taxable income is capped at £160,000, producing a fixed annual tax of £39,940 — a flat, predictable liability regardless of total worldwide earnings.

Component Amount
Minimum Gibraltar earnings Over £160,000 p.a.
Taxable income cap £160,000
Fixed annual tax £39,940

Ordinary residence

The 17 June 2026 residence framework.

Distinct from Category 2 and HEPSS, ordinary residence covers employed and self-employed applicants. On 17 June 2026 the Government published a new Residence Criteria framework that materially raised the bar for new applicants. It does not affect Gibraltar identity-card holders or persons resident before 6 October 2025, who remain under the earlier regime.

Salary

At least £37,500

A Gibraltar employment contract paying at least the average gross annual earnings — currently £37,500, rounded up to the nearest £500 and revised annually. Applicants under 30 may qualify below this where the employer pays tax and social insurance as if the threshold were met.

Employer

Established local business

The employer must have traded in or from Gibraltar for at least a year, be properly registered and licensed, and have its payments and filings up to date.

Accommodation

Rented or purchased

A rental of at least 12 months (no holiday lets) or a purchased property for use as the primary residence. No new applications are accepted from persons living aboard vessels.

Age & vetting

Generally 55 or under

Applicants must generally be aged 55 or under, subject to the Chief Minister's discretion, and must provide an official vetting form from their country of origin.

Fees

£250 application, £100 renewal

An application fee of £250 and an annual renewal fee of £100. Self-employed applicants and new businesses must lodge a deposit covering estimated first-year tax and social insurance.

Gibraltarian status

20 years for new applicants

Residence alone does not confer access to publicly funded services reserved for those with Gibraltarian Status. The qualifying period is now 20 years for new applicants (10 years for those resident before 6 October 2025).

For the applicant's adviser

If you're advising a client on Category 2.

A Cat 2 application sits in the middle of a wider relocation decision that the applicant's own legal, tax, and wealth advisers should be coordinating. We act as the Gibraltar introducer, prepare the Finance Centre application pack, and run the post-relocation residency administration. We do not displace existing advisers; we operate alongside them, on terms agreed up front.

What we provide alongside the applicant's advisers

  • Pre-application eligibility assessment delivered as a written note, suitable for sharing with the applicant's UK or other tax counsel.
  • Full Cat 2 application pack: source-of-wealth file, identity documents, property documents, professional references, and the application form.
  • Coordination with property search, conveyancing, and banking introductions in Gibraltar — without acting as estate agent or taking property commission.
  • Direct handling of Finance Centre correspondence and any due-diligence queries during government review.
  • Post-relocation: annual Cat 2 maintenance, Income Tax Office registration, and ongoing residence-evidence support.

What an adviser should brief the client on before referral

  • The approximate £37,000 annual minimum tax (rising to a practical maximum of around £42,380) is a real liability, paid every year, not a notional rate. A refundable £42,380 deposit and a £5,000 non-refundable application fee also apply.
  • Cat 2 by itself does not end home-country tax residency — the UK statutory residence test (and equivalents elsewhere) must be planned and evidenced independently.
  • Existing trust, foundation, and corporate structures should be reviewed before relocation, not after — moving residency can trigger structural reviews under the home jurisdiction's anti-avoidance rules.
  • Genuine residence is expected. Day-counting, lifestyle evidence, and presence in Gibraltar matter; a paper Cat 2 with no physical presence will not survive scrutiny.
  • Cat 2 holders generally cannot trade or take employment in Gibraltar. If the client's plan includes local business activity, that needs raising at the outset.
  • Category 2 is a tax-status certificate, not a residence permit. Note also the temporary suspension of new residency applications by UK, EEA and Swiss nationals in force since 6 October 2025, subject to narrow discretionary exceptions.

Arrange a confidential consultation.

Cat 2 is a significant personal decision with long tail consequences for the applicant and their family. A short, confidential initial conversation — without obligation — is usually enough to surface whether Category 2 fits the applicant's circumstances or whether a different arrangement is the right answer.

Arrange a consultation