Category 2 (Cat 2) and HEPSS are Gibraltar’s best-known specialist tax residency routes for high-net-worth individuals and senior executives.
Category 2 is generally aimed at high-net-worth individuals who do not intend to work locally, while HEPSS is designed for senior executives and specialists employed by qualifying Gibraltar companies. Both offer capped, more predictable tax exposure, but the eligibility rules, employment position, and application routes are different.
For many applicants, the real question is not whether Gibraltar offers a tax-efficient route, but which route applies to them. Choosing the wrong structure can delay approval, restrict employment, or create avoidable tax complications.
Category 2 Gibraltar & HEPSS — At a glance
- Category 2 tax position: assessable income capped at £118,000 per annum under the Allowance Based System.
- Category 2 annual tax liability: minimum £37,000, maximum £42,380.
- HEPSS tax position: gross assessable employment income capped at £160,000 per annum under the Gross Income Based System.
- HEPSS annual tax liability: £39,940 at current published rates.
- Best fit: Category 2 is generally for high-net-worth non-working residents; HEPSS is for senior executives working for qualifying Gibraltar employers.
- Both routes: require approved accommodation, formal approval, and ongoing compliance.
Category 2 Gibraltar offers a minimum annual tax of £37,000 and a maximum of £42,380, with assessable income capped at £118,000. HEPSS offers a capped tax position on employment income up to £160,000, typically resulting in an annual liability of £39,940 at current rates.
This guide is for general information only and does not constitute legal, tax, or immigration advice.
Updated 18 June 2026: This guide reflects the Government's announced changes to the Category 2 regime — a higher minimum net-worth requirement and application fee for new applicants (see the update note below). The tax figures shown reflect the current published position of the Gibraltar Income Tax Office and are unchanged by that announcement. Professional advice should always be obtained for individual circumstances.
Category 2 and HEPSS sit within the wider process of moving to Gibraltar, alongside employment, retirement, and Gibraltar residency planning.
What Is Category 2 Gibraltar?
Category 2 and HEPSS are not the same thing. They are separate Gibraltar tax residency routes created for different applicant profiles.
Category 2 is generally intended for high-net-worth individuals who establish residence in Gibraltar and want a predictable, capped personal tax exposure, while not taking up ordinary local employment.
What Is HEPSS in Gibraltar?
HEPSS (High Executive Possessing Specialist Skills) is a Gibraltar tax status designed for senior executives or specialists employed by qualifying Gibraltar companies, with a capped tax exposure on employment income.
In simple terms, Category 2 is usually the route associated with private wealth and lifestyle relocation, while HEPSS is linked to executive employment in Gibraltar.
Category 2 Gibraltar Requirements (2026)
Category 2 status is generally intended for high-net-worth individuals establishing Gibraltar as their principal place of residence. The commonly referenced requirements include the following:
Eligibility Criteria
- Minimum net worth of £5 million for new applicants (raised from £2 million on 18 June 2026; existing Category 2 holders are grandfathered on the previous threshold), commonly referenced excluding Gibraltar property
- Approved accommodation in Gibraltar, whether by purchase or rental
- No Gibraltar residence in the preceding 5 years
- No ordinary local employment in Gibraltar, although investment activity may be permitted subject to the rules and approval
Updated 18 June 2026: the Government announced it is modernising the Category 2 regime — raising the minimum net-worth requirement for new applicants to £5 million (from £2 million) and the application fee to £5,000 (from £1,233). Existing Category 2 individuals will be fully grandfathered and unaffected by the new threshold. The changes also confirm that a person who does not maintain Category 2 status will not have a right to continue residing in Gibraltar, and that Category 2 status does not give entitlement to publicly funded schooling or healthcare. Source: HM Government of Gibraltar.
Minimum Tax for Category 2 Gibraltar
The point most applicants search for first is usually the tax position.
Under the current published position, Category 2 individuals are taxed under the Allowance Based System (ABS), with assessable income capped at £118,000 per annum.
- Minimum annual tax liability: £37,000
- Maximum annual tax liability: £42,380
This is one of the main reasons Category 2 continues to attract internationally mobile individuals seeking more predictable personal tax exposure.
Gibraltar is also generally known for having no capital gains tax and no estate duty, based on Gibraltar government information. Broader tax planning, however, still depends on residence, source of income, and interaction with other jurisdictions.
For a broader understanding of how these caps sit within the overall framework, see our Gibraltar tax system guide.
HEPSS Gibraltar: Requirements and Tax Position
HEPSS is designed for executives and specialists employed by qualifying Gibraltar companies. Unlike Category 2, employment is central to the structure.
Key Requirements
- Senior management or technical position
- Skills considered essential to the company’s operations
- Employment contract with a qualifying Gibraltar company
- Approved accommodation and formal status approval
Tax Benefits (Current Position)
- HEPSS individuals are taxed under the Gross Income Based System (GIBS)
- Gross assessable employment income covered by the HEPSS certificate is capped at £160,000 per annum
- Annual total tax liability: £39,940 at current published rates
- Relocation and benefits packages may apply, depending on employer policy and taxation treatment
HEPSS is therefore usually relevant where a business is bringing a senior executive or specialist to Gibraltar, rather than for a private wealth relocation without local employment.
Cat 2 vs HEPSS: Key Differences
| Feature | Category 2 Status | HEPSS Status |
|---|---|---|
| Target applicant | High-net-worth individuals | Senior executives / specialists |
| Employment in Gibraltar | Not generally permitted | Required with qualifying employer |
| Assessable income cap | £118,000 | £160,000 |
| Tax liability | Minimum £37,000 / Maximum £42,380 | £39,940 annual total tax liability |
| Main use case | Private wealth and lifestyle relocation | Executive employment relocation |
Which Route Is Better: Category 2 or HEPSS?
Category 2 is usually the better fit where the applicant is relocating private wealth, does not intend to take up ordinary local employment, and wants a capped, more predictable personal tax outcome.
HEPSS is usually the better fit where the move to Gibraltar is driven by a senior executive or specialist employment role with a qualifying company.
For many applicants, the correct route depends less on preference and more on facts: wealth profile, employment plans, accommodation, family structure, and tax residence elsewhere.
How to Apply for Category 2 Status in Gibraltar
- Review whether Category 2 or HEPSS is the appropriate route for your circumstances
- Prepare financial, identity, and supporting eligibility documents
- Secure approved accommodation in Gibraltar
- Submit the application through an authorised adviser or agent
- Await decision and complete any follow-up compliance requirements
Timelines vary depending on the route, documentation, and the specifics of the application.
Looking for Cat 2-approved accommodation?
Browse our current Cat 2-eligible properties for sale or explore available Cat 2-eligible properties for rent across Gibraltar.
Frequently Asked Questions
What is the minimum net worth for Category 2 status in Gibraltar?
From 18 June 2026, new applicants must demonstrate a minimum net worth of £5 million (increased from £2 million), commonly referenced excluding Gibraltar property. Existing Category 2 holders are fully grandfathered on the previous £2 million threshold.
What is the minimum tax for Category 2 Gibraltar?
Under the current published position, the minimum annual tax liability for Category 2 is £37,000, with a maximum of £42,380, and assessable income capped at £118,000.
How do you apply for Category 2 status in Gibraltar?
You generally apply through an authorised adviser or agent, prepare identity and financial documents, secure approved accommodation in Gibraltar, and submit the application for formal approval. Timelines vary depending on the complexity of the case.
Can I work in Gibraltar with Category 2 status?
Category 2 is generally intended for individuals who do not take up ordinary local employment in Gibraltar, although investment activity may be permitted subject to the rules and approval.
What does HEPSS mean in Gibraltar?
HEPSS stands for High Executive Possessing Specialist Skills. It is a Gibraltar tax status designed for senior executives or specialists employed by qualifying Gibraltar companies.
Can HEPSS applicants bring family members?
Immediate family members, including a spouse and dependent children, can generally be included in both Category 2 and HEPSS applications, subject to the applicable requirements.
Speak to Century 21 Gibraltar
Where approved accommodation is part of the wider relocation plan, our team can help you identify suitable property options and guide you through the practical side of relocating to Gibraltar.
Author: Joyce Newman
Information correct at time of publication. Professional advice should always be obtained.
