Residency
Gibraltar has different tax-status and immigration arrangements. Category 2 applies a particular personal-tax calculation to qualifying individuals; HEPSS is a separate regime for senior executives with specialist skills. Ordinary immigration residence must be assessed on its own terms. Category 2 and HEPSS certificates are tax-status documents, not residence permits. We coordinate applications alongside the applicant's chosen legal and tax advisers and assist with relocation.
Law and published policy are different. LN 2026/127 increased the non-refundable Category 2 application fee to £5,000 from 22 June 2026. Separately, the Government announced a £5 million minimum net-wealth criterion for new applicants and grandfathering for existing holders. The numerical wealth criterion does not appear in that legal notice; confirm current application policy with the Finance Centre. Category 2 is a tax certificate, not itself a residence permit.
Category 2 · What it is
Under the Qualifying (Category 2) Individuals Rules 2004, the ordinary Category 2 calculation applies income-tax rates to the first £118,000 of taxable income and sets a £37,000 annual minimum for a full later year. Rule 10 separately addresses Gibraltar property income and income from permitted local activity; the cap is not a ceiling on every possible liability.
Specified foreign dividends, pensions and emoluments of office are excluded from Category 2 assessable income unless elected in under rule 10. Other receipts need source-specific analysis. Gibraltar has no capital gains tax, inheritance tax, wealth tax or general VAT regime; Transaction Tax applies to relevant goods.
Category 2 is not a residence permit. Local trade or employment requires the Finance Centre Director's permission and may give rise to separate Gibraltar-source tax under rules 5 and 10.
Applicants should consider their income sources, approved accommodation and continuing conditions, as well as their separate immigration and overseas-tax positions.
Category 2 · Eligibility
The Category 2 Rules address approved accommodation, previous presence and activity in Gibraltar, and the Finance Centre Director's assessment of financial standing and character. The Government separately announced a numerical wealth policy for new applicants in June 2026.
Net worth
The Government's June 2026 announcement raises the minimum net wealth criterion for new applicants from £2 million to £5 million and says existing certificate holders are grandfathered. The Category 2 Rules instead require the Finance Centre Director to assess substantial and sound financial standing without stating a numerical figure. Confirm the applicable evidence and current policy before applying.
Prior residence
Rule 4 generally excludes applicants who, in the previous five years of assessment, were present in Gibraltar for more than 183 days in any one year or an average of 90 days in any three years, or carried on local work. Incidental overseas-business activities and the Director's statutory waiver power may affect the outcome.
Property
Approved residential accommodation must be available for the applicant's exclusive use for the relevant period. A purchase is not inherently required; confirm whether the proposed lease or property meets the Director's approval criteria.
Local activity
Rule 5 allows the Finance Centre Director to permit local trade, business or employment if satisfied it benefits Gibraltar's economic development. Income from permitted activity is separately assessed under rule 10; discuss any proposed role before applying.
Category 2 · Tax structure
The Category 2 tax calculation is governed by the Qualifying (Category 2) Individuals Rules and the Income Tax Act. The table distinguishes the ordinary capped calculation from income assessed separately under rule 10. Resilience does not give individual tax advice.
| Component | Treatment | Indicative amount |
|---|---|---|
| Assessable income cap | Rates apply to the first £118,000 of taxable income under rule 9(4)(a), subject to the separate rule 10 treatment below. | £118,000 |
| Minimum annual tax | Statutory minimum for a full later year; first and final years are calculated for each complete or part month in force. | £37,000 |
| Other chargeable income | Gibraltar-property income and income from permitted Gibraltar activity are assessed under rule 10 and may give rise to tax outside the ordinary cap. | Case-specific |
| Specified foreign income | Rule 10(1) excludes specified foreign dividends, pensions and emoluments of office unless the holder elects to include them. | Source-specific |
| Application fee | Non-refundable; enacted by LN 2026/127 from 22 June 2026 (previously £1,233). | £5,000 |
| Refundable deposit | Rule 8 requires an advance tax payment; the current amount should be confirmed with the Finance Centre and is distinct from the application fee. | Confirm amount |
Last reviewed: 25 September 2026. Read the rules and confirm the current application requirements and advance payment with the Finance Centre. General information only; individual tax and immigration outcomes require separate advice.
Category 2 · Timeline
Processing depends on documentation, accommodation and the authorities' assessment. The stages and week ranges below are illustrations for planning, not a promised approval timetable; confirm current processing expectations before relying on a relocation date.
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.
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.
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.
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.
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
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.
For HEPSS, the qualifying employment income subject to Gibraltar assessment is capped at £160,000. Other income may be assessable separately; do not treat this as a cap on all worldwide income.
| Component | Amount |
|---|---|
| Minimum Gibraltar earnings | Over £160,000 p.a. |
| Taxable income cap | £160,000 |
| Qualifying employment income tax illustration | £39,940 |
Ordinary residence
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
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
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
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
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
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
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
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.
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.
