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Amicorp Malta Limited

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Amicorp Malta Limited

Overview:

A full European Union member since 2004, Malta’s advantageous tax regime, coupled with an extensive network of double tax treaties, has made it a jurisdiction of choice in various economic sectors for international clients. With its unique tax system, Malta is considered as an attractive EU jurisdiction for tax planning purposes.

Maltese companies are taxed at a flat rate of 35%, allowing for deductibility of expenses incurred in producing income, including interest on debt financing, and allowing unutilized losses to be carried forward unlimitedly to future years.

However, a refund amounting to 6/7 of the tax paid at company level is generally payable to shareholders of the Maltese company upon a dividend distribution. An advantage here is that such income, which is deposited in the company’s bank account, is not subject to further tax in Malta. Therefore, while the company does not receive any tax benefits, its shareholders are legally entitled to receive a refund of the tax paid in Malta, resulting in an effective Malta tax rate of only 5%.

In addition, Malta has an attractive participation exemption regime that exempts from tax any gains or dividends derived from a participating holding or from the disposal or part disposal of such holding. The participation exemption is not limited to participation holdings incorporated and resident in European jurisdictions, but can be extended to other jurisdictions, subject to specific anti-abuse provisions.

Other key features of the Maltese tax legislation that should be taken into account when setting up a structure in Malta are:

   No withholding tax on interest dividends and liquidation proceeds paid to non-residents;
   No thin capitalization rules;
   No specific transfer pricing rules;
   No uncontrolled foreign company legislation;
   Possible exemptions from the requirement of preparing consolidated financial statements at the level of the Maltese parent company;
   No exit taxes.

Malta offers foreign investors the security and ease of operating within EU borders, within easy reach of the emerging markets of North Africa and the Middle East, supported by a top-class legislative framework, a stable political and economic environment, and a cost-effective, driven workforce. Malta's rapid advancement, combined with an efficient business climate and excellent infrastructure in a relaxed Mediterranean setting, provides a unique opportunity for foreigners to do business under the sun.

For more information about structuring with Malta and Amicorp Malta, please see the specialized Amicorp brochure.

Languages spoken: English, Maltese and Italian

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