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 illustrations with respect to Interest Deduction Limitations and CFC provisions. As regards Exit Tax, the guidelines make it clear that this new concept has to be interpreted by keeping in mind local tax provisions such as certain capital gains exemptions.
The guidelines are available on the website of the Office of the Commissioner for Revenue.