Corporate Tax 2024 Practice Guide | Chambers And Partners

Camilleri Preziosi Advocates


Camilleri Preziosi commands an outstanding reputation amongst clients and peers as a leading Maltese corporate law firm. We are regularly ranked as a top-tier firm by Chambers, IFLR1000 and Legal 500. We retain a strong commitment to deliver a quality service in the practice of law. We do this by combining technical excellence with a solution-driven approach. Camilleri Preziosi: Technical excellence, practical solutions.
Donald Vella, Kirsten Debono Huskinson and Gabriella Chircop have contributed, once again, the Malta Chapter to the Corporate Tax 2024 Global Practice Guide, published by Chambers and Partners.
Malta Tax
To print this article, all you need is to be registered or login on

Donald Vella, Kirsten Debono Huskinson and Gabriella Chircop have contributed, once again, the Malta Chapter to the Corporate Tax 2024 Global Practice Guide, published by Chambers and Partners.

In summary, the Guide covers the following topics:

Types of Business Entities, Their Residence and Basic Tax Treatment

Corporate structures and tax treatment; transparent entities; determination of tax residence of incorporated businesses; applicable income tax rates.

Key General Features of the Tax Regime Applicable to Incorporated Businesses

The calculation of taxable profits including deductibility of allowable expenses; special incentive schemes that are available to support companies investing in research and development in different areas of science and technology; basic rules on loss relief; the limitations imposed on deduction of interest; basic rules on consolidated tax grouping; taxation of capital gains, imposition of stamp duty, VAT and customs duties.

Division of Tax Base between Corporations and Non-Corporate Businesses

The tax treatment relating to the payment of dividends by a Maltese company, including the full imputation system and tax refund mechanism; the tax treatment of a sale of shares held by individuals in closely held corporations versus publicly traded corporations.

Key Features of Taxation of Inbound Investments

Imposition of withholding taxes on dividends and payments of interest or royalties from a Maltese company to a resident or non-resident person; Malta's tax treaty network; principal purpose test; transfer pricing issues and disputes.

Key Features of Taxation of Non-Local Corporations

Difference in tax treatment of local branches versus local subsidiaries; capital gains accruing to non-residents; change of control provisions; constraints on related-party borrowing.

Key Features of Taxation of Foreign Income of Local Corporations

Tax treatment of foreign income generated by Malta tax resident companies; applicability of the participation exemption; taxation of dividends from foreign subsidiaries; taxation of gains derived from the transfer of intellectual property or profits from royalties derived from the licensing of intellectual property.

Anti- Avoidance

General anti-avoidance rule under Maltese Income Tax Act; ATAD anti-abuse measures including interest limitation rules, exit tax rules, general anti-avoidance rule, controlled foreign corporation rules, rules on hybrid mismatches.


Implementation of the OECD's Base Erosion and Profit Shifting (BEPS) Project's action points; the ratification of the Multilateral Instrument; adoption of the EU Minimum Tax Directive (Pillar Two), transfer pricing changes; transparency and country-by-country reporting.

You can view the full chapter by clicking here.

Reproduced with permission from Chambers and Partners. This Guide was first published in Chambers and Partners Practice Guides.

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.

See More Popular Content From

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More