Corporate Tax Comparative Guide

1 Basic framework

1.1 Is there a single tax regime or is the regime multi-level (eg, federal, state, city)?

Malta has a single tax regime, regulated mainly by:

• the Income Tax Act, Cap 123; and
• the Income Tax Management Act, Cap 372.

The regime is administered by the commissioner for tax and customs.

1.2 What taxes (and rates) apply to corporate entities which are tax resident in your jurisdiction?

Corporate entities (and other persons) are subject to taxes on:

• all income;
• certain capital gains; and
• the transfer value of immovable property situated in Malta.

The generally applicable tax rate for corporate entities in Malta is 35%. This applies to most types of income and capital gains chargeable to tax. The tax rate applicable to the transfer value of immovable property situated in Malta is 12% in most cases but can be reduced to 10% or 7% in certain circumstances.

1.3 Is taxation based on revenue, profits, specific trade income, deemed profits or some other tax base?

Corporate entities are normally charged tax on their chargeable income, consisting of income and capital gains, less allowable deductions and exemptions (ie, on the resulting profit).

The tax charged on the transfer value of immovable property situated in Malta is based on revenue (or deemed market value).

1.4 Is there a different treatment based on the nature of the taxable income (eg, gains on assets as opposed to trading income or dividend income)?

The tax is in general one and the same, but the determination of chargeable income may differ from the determination of a taxable capital gain. This may affect:

• the determination of tax liability;
• how gains or income is computed;
• exemptions and deductions;
• the tax treatment of losses; and
• tax jurisdictional rules.

1.5 Is the regime a worldwide or territorial regime, or a mixture?

Malta charges tax on the basis of:

• territoriality;
• ordinary residence;
• domicile; and
• remittance.

Briefly, Malta taxes:

• income and taxable capital gains arising in Malta;
• income and taxable gains arising outside Malta to a corporate entity tax resident and domiciled in Malta; and
• income (but not capital gains) arising outside Malta to an entity which is tax resident but not domiciled in Malta, if such income is received in Malta.

In other words, a corporate entity registered and tax resident in Malta is normally subject to tax on a worldwide basis. However, a participation exemption for dividends from a participating holding is available, making dividend taxation more territorial in nature. Furthermore, a non-Maltese corporate entity registered as tax resident in Malta may be taxed on foreign-sourced income on a remittance basis.

1.6 Can losses be utilised and/or carried forward for tax purposes, and must these all be intra-jurisdiction (ie, foreign losses cannot be utilised domestically and vice versa)?

Losses incurred in a trading activity are normally allowed as a deduction (had they been taxable if the loss were a profit). Trading losses can be carried forward to subsequent years (without any time limit) and may be offset against any taxable income and/or chargeable capital gains (except for income allocated to the final taxed account).

Any loss resulting from a capital transaction which would have been taxable had it been a gain may be offset against other capital gains, but not against trading income. Such losses may be carried forward to subsequent years (without any time limit) and may be offset against any chargeable capital gains (but not against any other taxable income).

1.7 Is there a concept of beneficial ownership of taxable income or is it only the named or legal owner of the income that is taxed?

The income of a trust may in certain circumstances be charged to tax in the hands of the trustee; but otherwise, taxable income is normally charged to tax in the hands of the named or legal owner of the income.

1.8 Do the rates change depending on the income or balance-sheet size of the taxpayer?

No, the rates do not change depending on the size of income or balance sheet.

1.9 Are entities other than companies subject to corporate taxes (eg, partnerships or trusts)?

The following may be subject to corporate taxes depending on the circumstances:

• any body corporate – including a company, partnership en nom collectif, partnership en commandite and any other partnership registered under the Civil Code; and
• any fellowship, society or other association of persons, whether corporate or incorporate and whether vested with legal personality or not.

A Maltese foundation is treated for tax purposes as if it were a company ordinarily resident and domiciled in Malta (unless the administrator of a foundation has irrevocably elected to be taxed under the provisions applicable to trusts). The trustee of a trust may also elect for the trust to be taxed as a company.

2 Special regimes

2.1 What special regimes exist (eg, for fund entities, enterprise zones, free trade zones, investment in particular sectors such as oil and gas or other natural resources, shipping, insurance, securitisation, real estate or intellectual property)?

There are a number of special regimes in the Income Tax Act, including the following:

• Collective investment schemes (funds): Funds are subject to particular tax accounting rules (eg, no income is allocated to the foreign income account). Funds that are not established as companies will be treated as companies for certain tax purposes. A Malta fund will be considered as a 'prescribed fund' if the value of the assets situated in Malta is at least 85% of the total assets of the fund. A 'non-prescribed fund' is a fund where less than 85% of the total assets of the fund are situated in Malta. Non-prescribed funds are exempt from tax on income (barring any income from immovable property situated in Malta).
• Shipping activities: A licensed shipping organisation is exempt from paying tax on income derived from:
• • shipping activities; and
  • a number of related activities, such as capital gains and interest income relating to financing of shipping activities.
• Trusts: Special rules apply to:
• • the settlement of property on trust;
  • the taxation of income derived by trusts; and
  • the taxation of trusts.
• These vary depending on:
• • the location of the assets;
  • whether income is derived from Malta or from outside Malta; and
  • where the beneficiaries of a trust are resident for tax purposes.
• A trustee may elect for a trust to be taxed as a foundation.
• Inbound relocations: Assets belonging to corporate entities changing their residence or domicile to Malta, or a company to be registered in Malta resulting from a cross-border merger, may be revalued at market value upon registration in Malta.
• Foundations: The administrator of a foundation may irrevocably elect to be taxed under the provisions applicable to trusts.
• Petroleum profits: A special tax regime contemplating special deductions and a particular way of accounting for tax applies.
• Securitisation transactions: The applicable rules provide for special tax treatment for vehicles falling under the definition of a 'securitisation vehicle' in the law.
• Insurance companies: Companies which are in the business of insurance are subject to special tax accounting and computational rules.
• Investment managers: Companies holding an investment services licence are subject to special computational rules.

Other special rules include:

• tax credits for venture capital funds;
• financial leasing rules; and
• branches of overseas companies.

2.2 Is relief available for corporate reorganisations or intra-group transfers of companies and other assets? Please include details of any participation regime.

Intra-group transfers of taxable assets are exempt from tax. Similarly, exchanges of shares upon mergers, demergers, divisions, amalgamations and reorganisations are exempt from tax where such exchange does not produce any change in:

• the beneficial ownership; or
• the proportion of value owned by such beneficial owners.

An exemption from tax on income and/or capital gains derived by a company registered in Malta from a participating holding or from the disposal of such holding is in place. The participation exemption is optional. A 'participating holding' qualifies as such where it meets the following requirements:

• It is a holding of equity, giving the right to at least two of the following rights:
• • the right to vote;
  • the right to share in profits; and
  • the right to share in assets on a winding up; and
• The company in which the holding is held:
• • holds directly at least 5% of the equity shares in another company;
  • is entitled to call for and acquire the entire balance of equity shares in another company;
  • is entitled to first refusal in the event of a disposal/redemption/cancellation of shares in another company;
  • is entitled to sit on, or appoint a person to sit on, the board of directors of another company;
  • holds an investment representing a total value of at least €1,164,000 in a company and has held such investment for at least 183 days; or
  • holds shares for the furtherance of its own business and not for trading stock.

There are limitations to the participation exemption – for example, it does not apply to dividends from companies situated in a jurisdiction included on the EU list of non-cooperative jurisdictions.

The participation exemption cannot be claimed in respect of income derived from participating holdings in companies or limited partnerships that are resident in Mata.

In order to claim the participation exemption in respect of income from a participating holding, the company, limited partnership or collective investment vehicle must meet one of three conditions:

• It is resident or incorporated in a country or territory which forms part of the European Union;
• It is subject to foreign tax at a rate of at least 15%;
• It does not have more than 50% of its income derived from passive interest or royalties;
• The participating holding held by the company registered in Malta is not part of a portfolio of investments; and
• The company, limited partnership or collective investment vehicle in which the participating holding is held, or that company's passive interest or royalties, are subject to foreign tax at a rate of at least 5%.

2.3 Can a taxpayer elect for alternative taxation regimes (eg, different ways to calculate the taxable base, such as revenue-based versus profits based or cash basis versus accounts basis)?

In general, no such elections are available except:

• if a taxpayer is subject to a special tax regime (eg, the tonnage tax regime applicable to licensed shipping organisations); or
• in certain other circumstances, such as where a taxpayer is subject to tax on the transfer value of immovable property situated in Malta, in which case it may under certain conditions elect to be taxed on profits instead.

Furthermore, in certain instances, interest income may be taxed on a received basis.

2.4 What are the rules for taxing corporates with different functional or reporting currency from that of the jurisdiction in which they are resident?

The tax chargeable on the income of a company must be declared, determined, assessed and paid in the currency in which its share capital is denominated. Any refunds or repayments in respect of such tax will be made in the same currency in which such tax was paid.

2.5 How are intangibles taxed?

In general:

• royalties are charged to tax as income; and
• gains or profits arising from the transfer of ownership over any goodwill, business permits, copyright, patents, trademarks, trade names and any other intellectual property are taxed as capital gains.

Royalties, advances and similar income derived from patents in respect of inventions, copyrights and trademarks may be exempt, subject to prescribed rules. At the moment, such rules have only been issued with regard to income from qualifying patents, where the Patent Box Deduction rules allows for an additional 95% deduction on income generated from the patents, subject to certain parameters.

Expenditure of a capital nature on intellectual property used for the production of income is deductible, spread over at least three years.

2.6 Are corporate-level deductions available for contributions to pensions?

Yes, sums contributed by an employer to a pension may be deductible. Contributions paid to an employee's workplace pension scheme are tax deductible up to €2,000 per employee per annum. Furthermore, a tax credit of 25% is available for every contribution paid on behalf of an employee, subject to a maximum tax credit of €750 per employee per annum.

2.7 Are taxpayers from different sectors (eg, banking) subject to different or additional taxes or surtaxes?

No, other than taxpayers that are subject to a special tax regime (see above).

2.8 Are there other surtaxes (eg, solidarity surtax, education tax, corporate net wealth tax, remittance tax)?

In general, no. However, dividends paid from a company's untaxed account (ie, company profits that have not been subject to tax) to a Malta resident are subject to a 15% withholding tax.

2.9 Are there any deemed deductions against corporate tax for equity?

A notional interest deduction (NID) is applicable in Malta, aimed at approximating the tax treatment of equity with that of debt. Claiming NID is at the option of the taxpayer and the NID is calculated by multiplying the deemed notional interest rate by the balance of risk capital of the company at year end. 'Risk capital' includes:

• share capital;
• share premium;
• reserves;
• interest-free loans; and
• any other item shown as equity in the financial statements of the company.

The deduction cannot exceed 90% of chargeable income, but excess NID can be carried forward.

3 Investment in capital assets

3.1 How is investment in capital assets treated – does tax treatment follow the accounts (eg, depreciation) or are there specific rules about the write-off for tax purposes of investment in capital assets?

Capital allowances are available but frequently differ from the rate of depreciation under the relevant accounting treatment. Expenses for the repair of premises, plant or machinery employed in acquiring income are deductible, together with expenses expended for renewal, repair or alteration of any implement, utensil or article so employed.

The deduction in respect of wear and tear of any plant and machinery and any industrial buildings or structures is calculated on a straight-line basis. Different categories of plant and machinery are tax depreciate over different timespans, as follows:

• Four years:
• • Computers and electronic equipment;
  • Computer software;
  • Aircraft airframes;
  • Aircraft engines;
  • Aircraft engine or airframe overhauls;
  • Aircraft interiors; and
  • Other parts.
• Five years:
• • Motor vehicles (subject to restrictions of value); and
  • Other machinery.
• Six years:
• • Equipment used for the construction of buildings and excavation;
  • Catering equipment;
  • Communication and broadcasting equipment;
  • Medical equipment;
  • Air conditioners; and
    Equipment mainly designed for the production of water or electricity.
• Ten years:
• • Furniture;
  • Fixtures;
  • Fittings and soft furnishings;
  • Ships and vessels;
  • Lifts and escalators; and
  • Other plant.
• Fifteen years: Electrical and plumbing installations and sanitary fittings.
• Twenty years:
• • Cable infrastructure; and
  • Pipeline infrastructure

The wear and tear rate on industrial buildings and structures (including hotels, car parks and office business centres) cannot exceed 2% per annum (and is not available for the cost of the land on which the building or structure is on).

Total capital allowances may never exceed 100% of the cost of acquisition of the relevant asset. If an asset is disposed of, a balancing statement needs to be made, whereby:

• income is added (if disposed at more than the tax written-down value); or
• a deduction is added (if disposed at less than the tax written-down value)

3.2 Are there research and development credits or other tax incentives for investment?

Capital expenditure on scientific research is deductible and should be spread equally over the year in which it is incurred and the following five years. The Research and Development Regulations provide for tax credits in certain circumstances.

Support under the Invest – Support for Initial Investment Projects may be available for enterprises that carry out qualifying activities, such as:

• manufacturing;
• pharmaceutical manufacturing;
• research and development activities;
• industrial services;
• computer programming;
• audiovisual productions;
• certain educational activities; and
• certain hospitality activities.

The support may take the form of:

• tax credits;
• cash grants;
• subsidies on loan interest; and
• bank guarantees.

Assistance under the Malta Enterprise Act, the Business Promotion Act and the Business Promotion Regulations may reduce the corporate tax rate to 15% when combined with certain tax treaties.

A number of other schemes may provide tax and other benefits, such as;

• the Start-Up Finance Scheme;
• the Investment Aid for Energy Efficient Projects Scheme;
• the Seed Investment Scheme;
• support for digitalisation for small and medium-sized enterprises;
• capital investments and startups; and
• Innovate-Innovation Aid.

3.3 Are inventories subject to special tax or valuation rules?

If trading stock is sold outside the regular trade of the business, the sale value may be set by the commissioner for tax and customs. Inventory valuations at year-end are normally made at the lower of cost or market value, for both accounting and tax purposes. Last in, first out is not accepted for tax purposes.

3.4 Are derivatives subject to any specific tax rules?

Income from trading activities, including the trading of derivatives, is taxed in the normal manner. One would normally have to look at the underlying asset of the derivative to determine the tax treatment of the derivative.

4 Cross-border treatment

4.1 On what basis are non-resident corporate entities subject to tax in your jurisdiction?

As a rule, income and gains arising in Malta are taxed in Malta, regardless of the residence status of the owner of the income or gain.

Income from the following is subject to tax in Malta:

• immovable property situated in Malta;
• services performed in Malta;
• contracts executed in Malta; and
• services connected to immovable property situated in Malta.

4.2 What withholding or excise taxes apply to payments by corporate taxpayers to non-residents?

Exemptions from Maltese tax for non-residents include:

• receipts of interest, discounts, premiums and royalties (unless such receipts are connected to a trade or business performed in Malta through a permanent establishment in Malta); and
• gains or profits from transferring shares or securities in a Maltese company (unless the Maltese company owns immovable property situated in Malta).

Similarly, dividends paid to a non-resident owner of a Maltese company do not attract tax in Malta.

For payments that are not exempt as per the above, a withholding tax of 25% is applicable to payments of income that are subject to tax in Malta to a non-resident. The rate may be reduced or eliminated by application (normally where such non-resident is registered for tax in Malta and files tax returns showing such income).

Excise duty is chargeable in some cases, such as on certain energy products and alcoholic drinks.

4.3 Do double or multilateral tax treaties override domestic tax treatments?

Yes – once concluded, a treaty becomes law by order and overrides any provisions to the contrary in Maltese domestic tax law.

4.4 In the absence of treaties, is there unilateral relief or credits for foreign taxes?

Yes, unilateral relief provides relief for double taxation in a manner that is very similar to double taxation treaty relief and applies where there is no tax treaty in place.

In addition to unilateral relief, a flat rate foreign tax credit is available in certain circumstances for income allocated to a company's foreign income account (including passive interest and royalty income) and no evidence of tax paid outside Malta need be provided.

4.5 Do inbound corporate entities obtain a step-up in asset basis for tax purposes?

Yes, at the option of:

• the company becoming domiciled and/or resident in Malta for tax purposes; or
• the company resulting from a cross-border merger being domiciled and/or resident in Malta.

The step-up to market value must be made by a notice in writing filed with the commissioner for tax and customs.

4.6 Are there exit taxes (for disposed-of assets or companies changing residence)?

Malta has implemented the rules under the EU Anti-Tax Avoidance Directive with respect to exit taxation as of 2020. Tax on capital gains may apply where:

• an asset is transferred from a Malta head office to its permanent establishment outside Malta;
• an asset is transferred from a Malta permanent establishment to its head office outside Malta; or
• the tax residence of the entity owning the asset is transferred to a place outside Malta.

If there is no effective loss of right to tax for Malta, because a transaction would have been exempt from tax under domestic law, no exit tax will apply.

5 Anti-avoidance

5.1 Are there anti-avoidance rules applicable to corporate taxpayers – if so, are these case law (jurisprudence) or statutory, or both?

A number of specific anti-avoidance rules, together with more general rules on tax avoidance and tax evasion, are in place. The tax law distinguishes between:

• tax mitigation (which is permitted);
• tax avoidance (which may be illicit and attract additional tax consequences); and
• tax evasion (which is a criminal activity).

In general, when a person enters into an arrangement solely or mainly to obtain a tax advantage, this arrangement may be set aside for tax purposes. Malta has implemented the rules under the EU Anti-tax Avoidance Directive (ATAD) with respect to the general anti-abuse rules (GAAR) as of 2020.

A number of specific anti-avoidance rules are also in force – for example, with regard to:

• value shifting;
• de-grouping;
• surrender of losses; and
• advances to shareholders.

The anti-avoidance rules are mainly statutory, but case law is relevant, especially in the interpretation of the more general anti-avoidance provisions.

5.2 What are the main 'general purpose' anti-avoidance rules or regimes, based on either statute or cases?

The main rule in the Income Tax Act prescribes that "where any scheme which reduces the amount of tax payable by any person is artificial or fictitious or is in fact not given effect to, the Commissioner [for tax and customs] shall disregard the scheme and the person concerned shall be assessed accordingly".

Furthermore, where "any person, as a direct or indirect result of any scheme of which the sole or main purpose was the obtaining of any advantage which has the effect of avoiding, reducing or postponing liability to tax, or of obtaining any refund or set-off of tax", has obtained an advantage, the commissioner may nullify or modify such an advantage.

The ATAD GAAR empowers the commissioner to ignore an arrangement or a series of arrangements which:

• are put in place for the main or one of the main purposes of obtaining a tax advantage that defeats the object or purpose of a tax law; or
• are not genuine. A non-genuine arrangement is an arrangement that is not put in place for any valid commercial reason that reflects the economic reality.

5.3 What are the major anti-avoidance tax rules (eg, controlled foreign companies, transfer pricing (including thin capitalisation), anti-hybrid rules, limitations on losses or interest deductions)?

Malta has implemented the ATAD, which includes rules relating to:

• interest limitation;
• exit tax;
• controlled foreign company rules; and
• GAAR.

Malta has also implemented the ATAD 2 rules neutralising hybrid mismatches. Furthermore, Malta has published its own transfer pricing rules with effect from 1 January 2024. There are no thin capitalisation rules.

5.4 Is a ruling process available for specific corporate tax issues or desired domestic or cross-border tax treatments?

Advance revenue rulings are available with regard to:

• anti-avoidance rules;
• the definition of a 'participating holding';
• any tax treatment of any transaction which concerns any financial instrument or other security; and
• the tax treatment of any transaction which involves international business.

Rulings are binding on the commissioner for tax and customs for the lesser of:

• two years from the time of any relevant change in law subsequent to such ruling; or
• five years from the time of the ruling.

A taxpayer may apply to renew a ruling for a further period of five years.

5.5 Is there a transfer pricing regime?

Yes, the transfer pricing rules have been in effect for transactions in Malta since 1 January 2024. The rules are applicable to cross-border arrangements between associated enterprises. Small and medium-sized enterprises are excluded from the scope of the rules and de minimis thresholds (€6 million revenue, €20 million capital) apply.

5.6 Are there statutory limitation periods?

The commissioner for tax and customs may issue an assessment no later than five years from the end of the year in which a tax return is filed. However, in the event of partial disclosure or wilful provision of incorrect or misleading information, the limit does not apply.

With respect to payment of tax, additional tax, interest or penalties, an action may be taken up to eight years from the date on which such tax, additional tax, interest or penalty becomes due and payable. In the case of an assessment, an action may be taken up to eight years from the date on which an assessment becomes final and conclusive.

6 Compliance

6.1 What are the deadlines for filing company tax returns and paying the relevant tax?

In general, the tax return and self-assessment for companies must be submitted within nine months of the company's financial year end (ie, if the financial year end is 31 December, the return must be filed by 30 September the following year). Penalties for late filing apply.

Companies with a financial year end between 1 January and 30 June must file by 31 March the following year.

An extension for electronic filing has been granted in the last few years by giving an extra two months' grace period for filing.

Similarly, tax is payable within nine months of the company's financial year-end. No extension is given, even if the company files electronically. Interest for late payment applies.

Companies that have been granted a DDT10 exemption (eg, where the owners are non-resident) will have an extended deadline for paying the tax due – instead of nine months from the company's financial year-end, the deadline is 18 months.

Provisional tax payments based on the last filed income tax return of the company are due in:

• April (20% of the benchmark);
• August (30% of the benchmark); and
• December (50% of the benchmark).

The benchmark can be reduced. Provisional tax is not payable by companies that have been granted a DDT10 exemption.

6.2 What penalties exist for non-compliance, at corporate and executive level?

Penalties for late filing of tax returns start at €50 if filed within six months of the deadline, rising to €1,500 for a return which is more than 60 months late.

Interest for late payment of tax is calculated at 0.6% per month or part thereof (of the tax payable).

Directors may be held personally responsible for penalties for late filing (and even for the tax due plus interest thereon if the director had possession of company funds at any time that could have been used to pay the tax).

6.3 Is there a regime for reporting information at an international or other supranational level (eg, country-by-country reporting)?

Malta is a member of the European Union and applies reporting obligations under:

• the Foreign Account Tax Compliance Act rules;
• the Common Reporting Standard rules; and
• the Directive on Cross-Border Tax Arrangements (DAC) 6 and DAC7 rules.

Country-by-country reporting obligations are also applicable. DAC8 rules must be transposed into Maltese law by 31 December 2025.

7 Consolidation

7.1 Is tax consolidation permitted, on either a tax liability or payment basis, or both?

Apart from surrendering losses between group companies, income tax consolidation is possible in Malta. Companies forming part of a group may elect to be treated as a single taxpayer.

Fiscal units where the parent company is considered the principal taxpayer of the fiscal unit are possible if:

• the parent company holds at least 95% of the shares in the subsidiary; and
• the accounting period begins and ends on the same date.

8 Indirect taxes

8.1 What indirect taxes (eg, goods or service tax, consumption tax, broadcasting tax, value added tax, excise tax) could a corporate taxpayer be exposed to?

Value-added tax is applicable to supplies of goods and services in Malta. The standard rate is 18%. Certain supplies may be subject to lower rates (eg, 12% for the hiring of a pleasure boat, 7% for eligible accommodation and 5% for the supply of electricity).

Customs duties may apply to imports from outside the European Union of certain goods; and excise duties may apply to:

• energy products;
• alcoholic drinks;
• tobacco products; and
• mobile telephone services.

Property transfer tax may be applicable and stamp duty may apply to transfers of immovable property (usually 5%).

Employers are subject to making social security contributions when employing staff locally.

8.2 Are transfer or other taxes due in relation to the transfer of interests in corporate entities?

Stamp duty on transfers of marketable securities is charged at 2% (5% if the company owns immovable property in Malta). However, if the company or the seller or buyer of the security has obtained a DDT10 exemption (usually with non-Maltese ownership and/or business), the transfer should be exempt from stamp duty (unless the company owns immovable property in Malta).

Value shifting rules may also apply where the market value of shares held by a person in a company has been reduced as a result of a change in the issued share capital or in the voting rights of such company. Transferors may be exempt from capital gains tax under certain provisions of the Income Tax Act.

9 Trends and predictions

9.1 How would you describe the current tax landscape and prevailing trends in your jurisdiction? Are any new developments anticipated in the next 12 months, including any proposed legislative reforms?

Malta continues to implement EU directives and the European Minimum Tax Directive has now been transposed. Malta has announced that it will apply the derogation available for the Income Inclusion Rule and the Undertaxed Profits Rule for 2024.

10 Tips and traps

10.1 What are your top tips for navigating the tax regime and what potential sticking points would you highlight?

Malta continues to be well regulated and still applies an audit requirement for all companies' accounts (although there may be some exemptions in the future for smaller companies). Ensuring that book-keeping and accounting are up to date and filings of accounts, income tax returns and VAT returns are made on a timely basis will help to prevent headaches and avoid:

• penalties and fines – which can become large; and
• the personal liability of the company's directors.

The full implementation system looks to be here to stay, so tax efficiency is still possible when setting up a company in Malta.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.