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Archives for Expertise

Transfer Pricing Rules

Following the introduction of Article 51A of Income Tax Act as an enabling provision for the introduction of the transfer pricing and Advance Pricing Agreements, the Office of the Commissioner for Revenue published the draft Transfer Pricing Rules for public…

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Guidelines in relation to ATAD

Following the implementation of the EU Directive 2016/1164 (ATAD1) by means of Subsidiary Legislation 123.187, the Maltese tax authorities issued official guidelines with respect to the Interest Deduction Limitations, CFC and Exit Tax.   The guidelines also include examples and…

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Reduction in interest rate

By virtue of two separate legal notices, the interest on late payments of income tax and VAT has been reduced from 0.54% to 0.33% per month.  The change is effective from 1 January 2020.
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The Patent Box Regime

As from year of assessment 2020, any person incurring qualifying IP expenditure and from which qualifying IP income is derived, may claim a deduction which may reduce the chargeable income from qualifying IP by 95%.  The assets that are considered...
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Tax Consolidation in Malta

Following the publication of the Consolidated Group (Income Tax) Rules by means of Legal Notice 110 of 2019, Malta introduced fiscal unity rules providing for a consolidated tax group.  As a result, certain groups of companies may, from the year...
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Malta implements ATAD

Malta implemented the EU Directive 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (ATAD) by means of Legal Notice 411 of 2018 EU ATAD Implementation Regulations, 2018. ...
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Anti-Tax Avoidance Directive (ATAD)

During the Budget speech for 2019 presented on 22 October 2018, it was announced that Malta, like other EU Member States, will be implementing the EU Directive on Anti-Tax Avoidance, more commonly known as ATAD1.   Although no detailed provisions...
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Tax Disputes

Tax authorities are becoming increasingly rigorous not only on compliance but they are taking a more investigate approach on aggressive tax planning, use of structures in other jurisdictions, transfer pricing, bench-marking and also on unexplained wealth. As tax legislation and…

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Corporate Taxation

Malta has been an EU Member State since 1 May 2004 and the adoption of EU Directives coupled with a unique full imputation system of taxation as well as tax refunds has developed the country into an international financial centre. ...
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Corporate Matters

Malta, being an EU Member State since 1 May 2004, has established itself as an international financial centre.  The legislative framework is in conformity with EU law.  The Companies Act is modelled on the UK Companies Act and provides for...
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