Advantageous – Compliant – Legitimate – Tax Minimisation
Tax Advice & Structuring
An ex-British colony, now legitimate EU country with 100% EU & OECD compliance, Malta is the obvious choice to start or relocate your business, structure or hold assets, royalties & intellectual property. Malta may be used in used alone or in combination with another jurisdiction, whether it be your home or a 0% tax jurisdiction.
- Full imputation system and a refundable tax credit system – effective corporate tax rate of 5%
- Shareholder dividend tax of 0%
- Extensive – currently over 60 – double taxation treaties in force
- 100% EC & OECD compliant and legitimate tax regime
- 0% tax exemptions for IP royalties – patents and artistic copyright
- No withholding taxes
- A participating holdings tax exemption
- Tax exemption from income derived by collective investment schemes
- No transfer pricing regulations, or thin capitalisation rules
- No anti-controlled foreign corporation legislation
- Investment tax credits for investors and the film industry
- 4 types of relief: double taxation treaty relief, commonwealth relief, unilateral relief, flat rate foreign tax
- Advance rulings possible by the Malta Commissioner of Inland Revenue on international transactions, guaranteeing the tax situation for a minimum of five years – renewable for a further five year period
Limited Company – Tax Advantages
The company limited by shares is by far the most popular, tax efficient and flexible type of corporate organisation, not only in Malta but internationally.
As in other jurisdictions, any liability of the shareholders is limited to the value of their shares, providing comfort to such shareholders not matter what business venture that may be pursued.
Benefits of a Malta Limited Company
|Full imputation system with possibility of shareholders claiming the appropriate refund and reducing income tax on their dividends by 6/7ths to an effective tax rate of 5%.|
|No withholding tax on company dividend, interest or royalties||Share capital in any currency|
|Transfer of shares normally tax exempt for non-residents if Malta company owns no immovable property in Malta||Low VAT rate & simplified VAT registration|
|No restriction of ownership or transfer of immovable property outside of Malta||Re-domiciliation both in and out of Malta allowed|
|Licensed operations, such as financial & investment services, can offer their services in other EU states||Indefinite carry forward of trading losses|
|No transfer pricing rules||No thin capitalisation rules|
|Generous tax rebates and investment schemes offered by Malta Government and EU|
Directorship & Company Secretarial
A one person Malta company is allowed, along with a Company Secretary who must be a natural person. Acumum can provide Company Secretarial services and act as Directors, as well as provide a registered office address.
Low Regulatory Fees
The one – off fee payable to the Registrar of Companies upon incorporation is € 245.
The minimum authorised share capital that must be subscribed is €1,200 of which at least 20% must be paid up, so that €240 need be deposited into a bank account.
For companies subscribed to the minimum share capital, the Annual Return, which must be submitted each year detailing any changes to the companies’ capital structure, shareholders or officials is only €100.
Tax Advantages for Malta Holding Companies
Shares, money, IP, real estate, personal items – any asset – can be held by a tax efficient Malta Holding Company, protecting such assets from creditors.
Tax advantages include 0% income tax on dividends received from (as well as 0% tax on capital gains from sale of) a ‘participating holding’ – a subsidiary where it holds:
- 10% of equity
- investment of €1.164M for more than 183 days
- 0% capital gains on disposal.
- 5% tax relief levied on profits paid to shareholders via a dividend from non participating holdings.
- For IPs not within Malta’s royalty exemption a 10% tax on passive income will be applied, which can be further reduced by the flat rate foreign tax credit (‘FRFTC’) to 6.25%.
Malta Double Taxation Agreements
Malta is a signatory to over 70 double taxation agreements (DTAs) and counting.
Contact us on +356 2778 1700 or contact us on Skype ID: acumum to discuss your operations further.