Malta Treaty Company Formation

Home > Corporate > Treaty Companies

Treaty Jurisdictions

Double Taxation Agreement Networks

Malta Treaty Company Formation and Requirements

Malta has a treaty network covering over 70 countries and operates a full imputation tax system under which the effective corporate tax rate for a foreign shareholder can be as low as 5% following the application of the tax refund mechanism. Malta is an EU member state, providing access to EU directives including the Parent Subsidiary Directive and the Interest and Royalties Directive.

The Maltese full imputation system allows a shareholder refund of five sixths (or two thirds for passive income) of tax paid by the Maltese company, reducing the effective rate of tax significantly. The participation exemption is also available for qualifying holdings, providing full exemption on dividends and capital gains from qualifying participations.

Shareholder Refund Mechanism

Non-resident shareholders of a Maltese company are entitled to claim a refund of six sevenths of the tax paid on trading income, reducing the effective tax to approximately 5% of the pre-tax profit.

Participation Exemption

Malta's participation exemption applies to dividends and capital gains from qualifying shareholdings of at least 5% held for at least 183 days, provided the subsidiary is resident in a treaty country or pays tax at a rate of at least 15%.

No Withholding Tax

Malta does not levy withholding tax on dividends, interest, or royalties paid to non-resident shareholders or lenders, making it efficient for upstreaming profits to ultimate holding entities.

Formation Requirements

A private limited liability company (Ltd) in Malta requires a minimum of EUR 1,165 in share capital, at least one director and one shareholder, and a registered office in Malta.

Get in Touch

Contact Neptune Fiduciaries Group via info@neptunecorporate.com or visit our Contact Us page.

Speak to a Treaty Company
Expert Today

Our fiduciary specialists have guided investors across all major treaty jurisdictions to efficient and compliant holding structures. Let us help you plan with confidence.

Book a Consultation Chat on WhatsApp