Malta will be introducing transfer pricing rules with effect from 1 January 2024 following the publication of Legal Notice 284 of 2022 on 18 November 2022.   The rules apply to cross-border arrangements entered between associated enterprises.   The term associated…

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…

On 8 October 2021, the Organisation for Economic Co-Operation and Development (OECD) announced that a landmark reform in the international taxation sphere was agreed between 136 countries, including Malta, out of the 140 members of the OECD/G20 Inclusive Framework on…

Article 12(1)(u) of the Income Tax Act has been amended to limit the applicability of the participation exemption to income received from a participating holding which is not in a company resident in a country listed in the EU list…

As from 1 January 2021, royalties received by an individual in his capacity as author of a qualifying literary work may be taxed at a final tax rate of 15%.  If an individual opts to have such royalties taxed under…

The Commissioner for Revenue published guidelines on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements to compliment Subsidiary Legislation 123.127,  Cooperation with Other Jurisdictions on Tax Matters Regulations which in return transposed the tax initiatives taken at…

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…