Malta – Full Imputation Tax Regime
Malta’s competitive tax regime is based on a full imputation system. Tax on the profit paid by the company distributing dividends, is made available to the shareholder as a tax credit, to avoid double taxation on the same income (for the company and subsequently for the shareholder).
A shareholder receiving profit dividends can request a tax refund on those … more
Malta published new Patent Box Regime (Deduction) Rules in August 2019. The rules apply to relevant income derived from qualifying intellectual property (qualifying “IP”) as from 1 January 2019.
Qualifying Intellectual Property
Qualifying IP is defined as:
a patent or patents, whether issued or applied for (if applied for it assumes the patent is granted);
assets for which protection … more
The three Mediterranean countries of Cyprus, Malta and Portugal each offer attractive residence and citizenship programmes. This Article details the different criteria that are applicable and who the different programmes are available to.
Permanent Residence Permit
Malta Residence and Visa Programme
Any Jurisdictions … more
Malta is an attractive and progressive jurisdiction for company incorporations. Located within the EU, it is introducing new laws and regimes, on an on-going basis, to consolidate this position. New laws include ‘New Consolidated Group Rules,’ introduced in May 2019, and new ‘Patent Box Regime Rules,’ implemented in August 2019.
NEW CONSOLIDATED GROUP RULES
Malta Full Imputation Tax Regime … more
Measures are increasingly being taken to counteract tax avoidance and EU countries such as Portugal and Malta are fully committed to meeting these obligations, as evidenced by recent tax laws that they have introduced.
ATAD was presented as part of the European Commission Anti-tax Avoidance package, at the start of 2016. The objective is to create a ‘level playing field’ across … more
History – The ‘Substance Regime’
On 1st January 2019 the ”substance-based regime” was introduced into the Crown Dependencies (Guernsey, Jersey and the Isle of Man).
This has meant that since January 2019, companies engaging in “relevant activities” have had to demonstrate that they meet specific substance requirements, to avoid sanctions.
This ‘Order’ is in response to a comprehensive review, … more
Malta private foundations have been used for asset protection and succession planning for several years. Amendments, at the end of 2018 to the ‘Voluntary Organisations Act’ enable foreign organisations, including private foundations, to be redomiciled to Malta.
Malta foundations are governed by the ‘Civil Act’ and the ‘Voluntary Organisations Act’ and are constituted as a … more
Malta has established itself as an innovative island.
Practical, workable regulations have been successfully introduced for gaming and blockchain/crypto businesses and Malta is now preparing for the next generation of development within the financial service sector. New initiatives include Malta ‘FinTech Vision 2021’ and the ‘Artificial Intelligence Project’.
FinTech Vision 2021 … more
Malta is one of the countries most advanced in terms of legislation regarding crypto-currencies and has developed a pragmatic approach in relation to the taxation of this asset type.
The Malta Commissioner for Revenue has issued three guidelines regarding the tax treatment of distributed ledger technology (‘DLT’) assets. Each of the guidelines relates to a different tax: income tax, … more
IN588 Increasing Demand For Malta Freeport Services And Regulation Of Malta Free Zones To Promote Further Expansion
Malta’s Strategic Location in the Mediterranean
Malta is a country located in a strategic position in the middle of the Mediterranean. Due to its location Malta has been a major centre for maritime operations for generations. This historical heritage and robust transport links, via air and sea, help to make Malta an ideal hub to establish an international company.
Malta’s strategic geographical … more
A new legislative initiative in Malta means that it is now possible to grow and process cannabis (marijuana) in Malta, as long as it is for medical use. This presents an opportunity for entrepreneurs and investors.
Due to its geographical position Malta is also conveniently placed, as a potential distribution hub for medical cannabis.
Entities need to apply to produce and/or process … more
The Malta Commissioner for Revenue has just published the guidelines that are to be used to determine the place of supply for the hiring of pleasure boats. These will be applicable, retrospectively, for all leases commencing on or after 1 November 2018.
These new guidelines are based on the fundamental VAT principle of ‘use and enjoyment’ and provide the mechanism to determine the amount of VAT … more
As a member of the EU, Malta has implemented the EU Anti-Tax Avoidance Directive (ATAD) and has incorporated it into domestic legislation.
Malta incorporated the ATAD measures into its domestic legislation at the beginning of December 2018 through implementation of Legal Notice 411, which includes the following:
an interest limitation rule;
general anti-abuse rules (GAAR);
controlled … more
The Maltese Government is committed to promoting the film production sector and cash rebates can be claimed, as a financial incentive, to the growing Audio-visual Industry in Malta.
What Rebates are Available?
Starting from January 2019, qualifying companies can receive a maximum 40% cash rebate for film production in Malta.
The cash rebates are rebates on the expenses in Malta, … more
Over the past decade, Malta has consolidated its status as an international, Mediterranean centre of maritime excellence. Currently Malta has the largest shipping register in Europe and the sixth largest in the world. In addition, Malta has become a world leader in terms of commercial yacht registration.
In order to avoid the risk of shipping companies relocating or flagging to low-tax countries … more
The Maltese Government introduced modifications to the remittance basis of taxation on 1 January 2018.
Malta offers an extremely attractive remittance basis, whereby a resident non-domiciled individual is only taxed on foreign income if this income is received in Malta or is earned or arises in Malta.
A Tax Change for Resident Non-Domiciled Individuals
Changes, introduced at the … more
IN545 - Malta's Notional Interest Deduction Regime - Which Types of Company are Most Likely to Benefit?
Malta introduced the Notional Interest Deduction Regime (NID) on 1 January 2018. On 8 August 2018, the Guidelines in relation to NID were updated, in particular the treatment of NID between related companies.
What is NID?
NID is an innovative way in which companies can, in the correct circumstances, reduce their tax liabilities. This option is of greatest interest to companies with large equity … more
IN542 - The Maltese Parliament is Putting in Place the Foundations to Become the 'Blockchain Island'
Malta has, for several decades, been a country committed to new technologies and to welcoming investment in such sectors.
With blockchain it is no different.
At the end of June 2018, the Maltese Parliament unanimously approved three Bills:
The Virtual Financial Assets Bill.
The Technology Arrangements and Services Bill.
The Digital Innovation Authority Bill.
Each of these establishes … more
HN - Three Bills on ‘Distributed Ledger Technology’ (relating to Crypto Currency and Bitcoin) have been Approved by the Malta Parliament
On 26 June 2018, the Maltese Parliament unanimously approved three Bills.
The Virtual Financial Assets Bill -which provides regulation on virtual currencies and initial coin offerings (ICO)
The Technology Arrangements and Services Bill - which is concerned with the registration and certification of technology service providers
The Digital Innovation Authority Bill– which will establish the … more
In October 2017 the Government of Malta published a public consultation paper, proposing a new set of rules to regulate collective investment schemes using virtual currency. Further to industry responses, a feedback statement was issued in January 2018.
The Malta Financial Services Authority (MFSA) has developed and published a ‘rulebook’ to regulate Professional Investor Funds (PIFs) which … more
The Malta tax system is an efficient fiscal regime which, in particular when used in combination with Malta’s network of double tax treaties, offers a number of benefits to companies that are domiciled in Malta. Historically, however, this tax regime has suffered criticism and the labelling of Malta as a potential tax ‘haven’, resulted in an investigation by the European Investigative … more
IN489(P) - A New Residence Scheme in Malta and Favourable Changes to the Existing Residence and Visa Programme (Portuguese version)
NOVA VIA DE OBTENÇÃO DE RESIDÊNCIA EM MALTA E MUDANÇAS FAVORÁVEIS AO ACTUAL PROGRAMA DE RESIDÊNCIA E VISTOS
O novo programa, denominado "Iniciativa para Empregados Essenciais"/”Key Employees Initiative” em Malta permite a emissão de autorizações de trabalho e residência a futuros funcionários (desde que não residentes na UE) no prazo de cinco dias úteis a contar da data do pedido.
As … more
SOCIEDADES “HOLDING” DE MALTA - PORQUE SÃO TÃO ATRAENTES?
Vantagens para a localização de uma sociedade “holding” internacional
A localização de uma sociedade “holding” é uma consideração importante em qualquer estrutura internacional, onde um dos objetivos é optimizar o imposto cobrado sobre o fluxo de rendimentos.
Idealmente, a sociedade “holding” deve estar localizada numa jurisdição que: … more
IN489(S) - A New Residency Scheme in Malta and Favourable Changes to the Existing Residence and Visa Programme (Spanish version)
UN NUEVO ESQUEMA DE RESIDENCIA EN MALTA Y CAMBIOS FAVORABLES AL ACTUAL PROGRAMA DE RESIDENCIA Y VISAS
El nuevo programa 'Key Employee Initiative' en Malta permite la emisión de permisos de trabajo / residencia a potenciales empleados clave (que no sean ciudadanos de la UE) dentro de los cinco días utiles posteriores a la fecha de solicitud.
Los cambios al "Programa de Residencia y … more
EMPRESAS “HOLDING” EN MALTA: ¿POR QUÉ SON TAN ATRACTIVAS?
Características ventajosas para la ubicación de una empresa “holding” internacional
La ubicación de una empresa “holding” es una consideración importante en cualquier estructura internacional, donde uno de los objetivos es minimizar el impuesto aplicado sobre el flujo de ingresos.
Lo ideal sería que la empresa “holding” sea residente en … more
IN511 - New Malta-Ukraine Double Taxation Agreement Now Ratified and Additional Attractive Malta DTAs
A new Double Taxation Agreement between Malta and the Ukraine was ratified in 2017 and was made effective as from 1 January 2018.
As a result of this DTA, tax advantages for both countries are available and the Maltese holding company regime may prove attractive to Ukrainian investors. This DTA allows for dividends to be taxed in the country of source, at a withholding tax rate of 5%, if the … more
Malta introduced the Notional Interest Deduction Regime (NID) in October 2017. It comes into force at the start of the 2018 Maltese corporate tax year (1 January 2018).
What is NID?
NID is an innovative way for companies to reduce their tax liabilities. This option will be of greatest interest to companies with large equity balances.
NID allows companies to deduct a notional interest amount … more
Malta as a jurisdiction, with it generous and effective corporate tax system, is positioning itself as a leading Blockchain technology hub, with many state led initiatives currently underway.
Earlier this year the Maltese Government implemented a National Blockchain Strategy aimed at capitalising on the current opportunities for Malta to become a global Blockchain and Cryptocurrency front runner. … more
IN489 - A New Residence Scheme in Malta and Favourable Changes to the Existing Residence and Visa Programme
The new ‘Key Employee Initiative’ programme in Malta allows for work/residence permits to be issued to prospective key (non-EU) employees within five working days from the date of the application.
Changes to the Malta ‘Residence and Visa Programme’ now allow the applicant and main dependents to apply for long-term residence in Malta after five years of residence.
In addition, parents … more
Dixcart is licensed to provide fund administration services in Malta and in the Isle of Man.
We provide a comprehensive range of services in Malta including accounting and shareholder reporting, corporate secretarial services, fund administration, shareholder services and valuations.
The Benefits of Establishing a Fund in Malta
A key benefit in terms of using the jurisdiction of Malta for the … more
Malta offers five residence programmes to meet different individual circumstances. Some are appropriate for non-EU individuals while others provide an incentive for EU residents to move to Malta.
The five residence programmes and the tax benefits they can provide for individuals, where relevant, are detailed below.
INDIVIDUAL INVESTOR PROGRAMME
The Individual Investor Programme (IIP) … more
The location of a holding company is an important consideration in any international structure where one of the objectives is to minimise the tax charged on the income flow.
Beneficial Characteristics for the Location of an International Holding Company
Ideally the holding company should be resident in a jurisdiction which:
Has a good double tax treaty network, thereby minimising … more
Dixcart Business Centres offer extensive serviced office capacity and are ideal for companies establishing themselves in a new location. Dixcart Business Centres are located in Guernsey, the Isle of Man, Madeira (Portugal), Malta and the UK.
Business Centres can offer a productive work environment and a cost effective option for organisations with international interests wishing to operate from … more
A lot of uncertainty has been generated within Europe following on from the Brexit vote, and certain other countries who are beginning to reassess their position within the EU. This is having an impact on the marine industry, with a number of vessel owners seeking to reflag ships and yachts.
The choice of flag registration is an important decision and a jurisdiction must be selected that … more
Ideal Characteristics for the Location of an International Holding Company
The location of a holding company is an important consideration in any international structure where the objective is to minimise the tax charged on the income flow. Ideally the company should be in a jurisdiction which:
Has a good double tax treaty network, thereby minimising withholding taxes on dividends received. … more
IN380 - Foundations - Why? And Consideration of Various Jurisdictions: Guernsey, The Isle of Man, Malta and Nevis
Foundations are useful tools in terms of wealth management and asset protection. The jurisdictions of Guernsey, the Isle of Man, Malta and Nevis are attractive locations in which to establish a foundation. Each of these jurisdictions offer a number of potential advantages and the most appropriate jurisdiction will depend upon each specific situation.
Dixcart and Foundations
Dixcart can assist … more
Dixcart provides aircraft registration services in a number of jurisdictions. These jurisdictions have registries which offer a variety of advantages and tax efficiencies.
Dixcart can advise on aircraft registration and help coordinate the aircraft registration process in: Guernsey, the Isle of Man, Malta and Portugal. This can include establishing and administering the relevant ownership … more
The level of regulation within the e-gaming industry is constantly being reviewed to increase protection for users. Many of the less well regulated jurisdictions are beginning to find themselves less attractive to the major e-gaming organisations.
Agreement between the Isle of Man and Malta
The Isle of Man Gambling Supervision Commission and the Malta Lotteries and Gaming Authority entered … more
IN275 - A Consideration of Shipping in the Jurisdictions of Cyprus, the Isle of Man, Madeira (Portugal) and Malta
Dixcart can provide clients with a number of alternative ship registration solutions.
This note provides a brief overview of the shipping regimes in Cyprus, the Isle of Man, Madeira (Portugal) and Malta. More detailed information is available on request regarding shipping in each of the jurisdictions considered in this Article.
Cyprus is a major ship management centre attracting … more
It is possible for a company to be incorporated in one jurisdiction and to be resident in another. In certain circumstances this can generate tax efficiencies.
It is very important to always ensure that the company is properly managed and controlled from the jurisdiction in which it is resident.
The jurisdictions of Cyprus, Malta and the UK present a number of opportunities, as detailed below. … more
WHY USE MALTA?
The Republic of Malta is an archipelago consisting of the three inhabited islands of Malta, Gozo and Comino. The Maltese islands are situated in the middle of the Mediterranean Sea, about 100 km south of Italy.
Factors contributing to and enhancing the status of the jurisdiction include:
Malta is a member of the EU and therefore has access to European Union Conventions.
It … more