The Maltese Transfer Pricing Rules are effective from basis years commencing on or after 1st January 2024 and require the pricing of in-scope cross-border arrangements to be at arm's length for the purposes of computing the taxable income of relevant persons. The following is an overview of the salient features of the Maltese Transfer Pricing Rules to help you understand the applicability of these rules to your group.

The Maltese Transfer Pricing Rules apply in relation to cross-border arrangements:

  • Between associated enterprises.
  • Entered into on or after 1 January 2024 or arrangements entered into before 1 January 2024 but are materially altered on or after that date.


The Maltese Transfer Pricing Rules do not apply to:

1367816a.jpg Micro, small or medium-sized enterprises – the size of the enterprise is to be determined by reference to group-wide data as laid down in Annex I of Commission Regulation (EU) No 651/2014 of 17 June 2014.
1367816b.jpg Securitisation transactions in terms of the Securitisation Transactions (Deductions) Rules.
1367816c.jpg Persons whose aggregate arm's length value of all items of income and expenditure do not exceed EUR 6 million for transactions of a revenue nature and EUR 20 million for transactions of a capital nature.

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.