Malta is presented as an attractive location for holding companies and tax planning due to its low tax rates, robust tax system, and participation exemption regime which allows for dividends and capital gains to be exempt from Maltese tax. Key benefits include no withholding taxes on outbound payments, extensive double tax treaty network, and a refundable tax credit system which can result in an effective tax rate of 5% for shareholders. Malta is positioned as providing opportunities for EU market entry and exit in a tax efficient manner.
With 0% tax on patent and artistic royalties and 0-5% tax on on all other IP, Malta, an EU jurisdiction is now the best country to structure your IP assets.
A legitimate, fiscal & tax competitive EU jurisdiction.
5% effective corporate tax rate, no withholding, capital gains or entry or exit taxes. No inheritance or wealth taxes.
An overview of the laws and fiscal benefits of using Malta as an EU tax efficient jurisdiction for asset structuring, trusts and investment vehicles.
A legitimate low tax EU jurisdiction.
5% effective corporate tax rate, no withholding, capital gains or entry or exit taxes. No inheritance or wealth taxes.
In this webinar, our Managing Partner Frederico Gouveia e Silva presents the advantages of Malta as a competitive location for the management of international operations such as trading, holding, trusts and foundations, intellectual property and shipping.
UAE can be used favorably as the location for the ultimate holding company for a group that is relocating to a new jurisdiction or on formation of a new publicly traded entity with worldwide activities
With 0% tax on patent and artistic royalties and 0-5% tax on on all other IP, Malta, an EU jurisdiction is now the best country to structure your IP assets.
A legitimate, fiscal & tax competitive EU jurisdiction.
5% effective corporate tax rate, no withholding, capital gains or entry or exit taxes. No inheritance or wealth taxes.
An overview of the laws and fiscal benefits of using Malta as an EU tax efficient jurisdiction for asset structuring, trusts and investment vehicles.
A legitimate low tax EU jurisdiction.
5% effective corporate tax rate, no withholding, capital gains or entry or exit taxes. No inheritance or wealth taxes.
In this webinar, our Managing Partner Frederico Gouveia e Silva presents the advantages of Malta as a competitive location for the management of international operations such as trading, holding, trusts and foundations, intellectual property and shipping.
UAE can be used favorably as the location for the ultimate holding company for a group that is relocating to a new jurisdiction or on formation of a new publicly traded entity with worldwide activities
Following approval of the State Budget for 2014 by the Portuguese Assembly of the Republic and the reform of the corporate income tax, various changes have been made to the Portuguese tax regime, some of them of relevance to the International Business Centre of Madeira (IBCM). This presentation highlights the most relevant changes and its impact on the Madeira tax regime. Updated: January 30, 2014.
The attractive corporate tax of Cyprus and how local and international companies can benefit. Low corporate tax 12.5%
Tax Exemptions, Tax deductions, Losses carried forward.
Guide "Make a French Start" : The French tax systemNicolas Ribollet
Guide "Make a French Start" : The French tax system
Mazars and Business France combined their expertise to help foreign investors and entrepreneurs who want to settle in France. Mazars has created practical guides that we hope will provide you with valuable insight to launch and grow your business in France.
In associations with Croner Taxwise, the conference will provide a general tax update whilst also focussing on some more specific areas which appear to be causing problems for our consultancy clients.
Topics covered;
• Topical tax issues
• Requirement to Correct for offshore income and assets
• What should your Tax Fee Protection Insurance provider do for your practice?
• R & D tax relief claims
• VAT update including, land and property, possible Brexit landscape and disputes & resolutions
Trabalho de Inglês falando sobre o País Malta!
*English-workers talking about the country Malta!
Coloquei um vídeo em um dos slides, mas o tamanho excedeu, por tanto, deixarei disponível o link para vocês de um TOUR pelas cidadades de MALTA logo abaixo.
*I put a video on a slide, but the size exceeded, therefore, leave available to link to you in a TOUR by cidadades of MALTA below.
LINK==> https://www.youtube.com/watch?v=eQ6Uf8qeULY
Following approval of the State Budget for 2014 by the Portuguese Assembly of the Republic and the reform of the corporate income tax, various changes have been made to the Portuguese tax regime, some of them of relevance to the International Business Centre of Madeira (IBCM). This presentation highlights the most relevant changes and its impact on the Madeira tax regime. Updated: January 30, 2014.
The attractive corporate tax of Cyprus and how local and international companies can benefit. Low corporate tax 12.5%
Tax Exemptions, Tax deductions, Losses carried forward.
Guide "Make a French Start" : The French tax systemNicolas Ribollet
Guide "Make a French Start" : The French tax system
Mazars and Business France combined their expertise to help foreign investors and entrepreneurs who want to settle in France. Mazars has created practical guides that we hope will provide you with valuable insight to launch and grow your business in France.
In associations with Croner Taxwise, the conference will provide a general tax update whilst also focussing on some more specific areas which appear to be causing problems for our consultancy clients.
Topics covered;
• Topical tax issues
• Requirement to Correct for offshore income and assets
• What should your Tax Fee Protection Insurance provider do for your practice?
• R & D tax relief claims
• VAT update including, land and property, possible Brexit landscape and disputes & resolutions
Trabalho de Inglês falando sobre o País Malta!
*English-workers talking about the country Malta!
Coloquei um vídeo em um dos slides, mas o tamanho excedeu, por tanto, deixarei disponível o link para vocês de um TOUR pelas cidadades de MALTA logo abaixo.
*I put a video on a slide, but the size exceeded, therefore, leave available to link to you in a TOUR by cidadades of MALTA below.
LINK==> https://www.youtube.com/watch?v=eQ6Uf8qeULY
Curiosidades y características de Malta
1. (Foto)
2. Situación de Malta
3. Ubicación
4. Población
5. Bandera
6. Escudo
7. Referencias
8. Clima
9. Turismo
Aquí os dejo un pequeño resumen de toda la presentación.
A comprehensive guide to Malta's tax system for Malta trading companies.
Malta an EU country has the lowest effective corporate tax rates at 5% in the EU - a 100% EU & OECD Legitimate Tax System
Key Facts for Limited Companies in Malta; a legitimate low tax EU jurisdiction
5% effective corporate tax rate, no withholding, capital gains or entry or exit taxes. No inheritance or wealth taxes.
With a number of recent and upcoming developments in the OECD’s international tax work, we invite you to join a live webcast with experts from the Centre for Tax Policy and Administration for an update on the work relating to the tax challenges arising from the digitalisation of the economy.
Website: http://oe.cd/taxtalks
DMIEXPO - Arosal - Where To Hold Your IP: The A To Z Guide For Digital MarketersMorning Dough
Arosal will walk you through the challenges and pitfalls which characterize the global tax scene post-BEPS, specifically as regards IP Boxes and the so-called ‘Nexus’ approach. We shall walk you through the process of registering and protecting your IP, whilst designing a robust international structure which will stand up to any BEPS-related challenge.
Furthermore, Arosal will outline the services which you will require, and the process through which these will be obtained regarding the implementation of your structure, whilst focusing on the tax optimization of the group’s entire structure as concerns all types of taxes. Finally, we shall discuss the administration of your international structure, and comment on the way forward in the global market place.
Slides from IBSA Webinar - Double Tax Treaties: Asia & Europe which took place on 18 September 2014, presented by John Timpany of KPMG China and Roy Saunders of IFS Consultants. To view the webinar on demand, please visit our Bright Talk Channel at https://www.brighttalk.com/channel/11641
Democratic Alliance together with experts has developed a framework for the tax reform in Ukraine. Please find more details at http://dem-alliance.org/news/podatkova-reforma-ukraina.html.
Your comments and ideas are welcome, please send them to reforms@dem-alliance.org
As an EU outermost region, the Canary Islands have an Economic and Tax System (REF) of their own, fully approved by the EU, which applies double taxation conventions and fiscal transparency (Canary Islands Hub)
Taxation Comparison Between The United Kingdom and LithuaniaEvaldas Čerkesas
This presentation aims is to reveal main differences between corporate in personal taxation in the United Kingdom and Lithuania. This presentation could be useful for all who considers to receive more effective tax structuring.
The interaction between the extensive Portuguese Corporate Income Tax Reform of 2014 with the regime of the International Business Center of Madeira or Madeira Free Zone provides many interesting tax planning opportunities, namely an effective general Corporate Income Tax rate of 5% or a specific effective rate of 0,75% for certain Intellectual Property income. RPBA has fully updated its extensive presentation on this subject.
Malta's Intellectual Property Advantage: Tax Benefits and Legal FrameworkEMD Advocates
Malta has established itself as the perfect jurisdiction for the implementation of Intellectual Property Law throughout the years for a variety of reasons. Website : https://www.emd.com.mt/advocates/intellectual-property/
For advice on the main conditions to register holding companies in Lithuania, we invite you to contact our specialists, at https://www.companyformationlithuania.com/.
Real estate, as an immovable factor, tends to be overtaxed in most countries and Portugal is no exception. Tax structuring and optimizing is crucial to minimize total acquisition costs and maximize investment returns.
RPBA’s updated presentation deals with this challenging topic incorporating the latest developments, including tax incentives on rehabilitation, the OECD Multilateral Instrument rules on “real estate rich” companies and also the brand new SIGI company (the Portuguese equivalent of the REIT – Real Estate Investment Trust).
International Indirect Tax Update - March 2016Alex Baulf
In this VAT Club "International Indirect Tax Update" presentation, Grant Thornton UK LLP's Alex Baulf, Henry-Cairns-Terry and Ben Price, present an update on VAT, GST and Customs from across the globe. This includes:
1. EU case law and policy update
2. Union Customs Code update
3. New regimes, rates and rules
Slides are from Grant Thornton UK LLP's VAT Club seminar event held in London on 9th March 2016.
The company is a member firm of HLB International and has the global exposure to help entities comply with corporate tax, once it gets implemented in the year 2023.
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Explore our most comprehensive guide on lookback analysis at SafePaaS, covering access governance and how it can transform modern ERP audits. Browse now!
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The world of search engine optimization (SEO) is buzzing with discussions after Google confirmed that around 2,500 leaked internal documents related to its Search feature are indeed authentic. The revelation has sparked significant concerns within the SEO community. The leaked documents were initially reported by SEO experts Rand Fishkin and Mike King, igniting widespread analysis and discourse. For More Info:- https://news.arihantwebtech.com/search-disrupted-googles-leaked-documents-rock-the-seo-world/
Stephen Balzan. Malta where does the Russian money goes. The Future of Offshore Jurisdiction Malta 07.06.2013
1. WHERE DOES RUSSIAN MONEY
GO NOW?
THE FUTURE OF OFFSHORE
JURISDICTION
MALTA
Stephen Balzan
Tax Partner EMD
LEGAL TAX ADVISORY CORPORATE
16/26/2013
2. MALTA
■ A fully independent republic
■ EU Member State since 2004 and introduced Euro in 2008
■ Stable economy
■ Strong financial system
■ Economy dominated by manufacturing, tourism, financial
services and ICT sectors
■ Banking and finance regulations based on EU rules
■ Centre of the Mediterranean
■ No exchange controls
■ Free market economy
■ Safe environment
26/26/2013
3. MALTA
■ Democratic country
■ Flexible but well regulated environment
■ Efficient tax system
■ State of the art telecommunication systems
■ Excellent education sector
■ State of the art health sector
■ Safe environment to live and work
■ No uncertain tax positions
■ Reasonable cost of living
36/26/2013
4. MALTA
■ A reliable international business centre
■ Low running costs, rents and labour costs
■ Low registration fees and share capital
■ Extensive double taxation treaty network
■ Convenient time zone
■ Support services by pro-active professionals
■ A place where to combine work and pleasure
■ A very mild winter ……. and a very hot summer
46/26/2013
5. THE ECONOMY
■ Currency – Euro since 2008
■ GDP in 2012 – 8.6 billion Euros
■ Economic growth in 2012 – 1.2 %
■ EU forecasts that Malta will register the second highest growth
among the 17 members of the Eurozone
■ Unemployment in April 2013 – 5.5%
■ Lowest effective tax rate in the European Union
56/26/2013
6. THE ECONOMY
Main contributors to GDP:
■ Tourism (35%) - over 1.3million visitors annually
■ Industry (27%)
■ Financial services (15%) - over 7,000 employed. In
the next few years, this is expected to increase to 25%
of GDP
66/26/2013
7. Standard corporate income tax rates
Malta 35%
UK 24%
Germany 15%
Italy 27.5%
Belgium 34%
Estonia 21%
Luxembourg 21%
Cyprus 10%
76/26/2013
8. Corporate income tax rate is 35%. However, the
combined overall Malta effective tax (COMET) rate is
reduced by the application of:
86/26/2013
Full Imputation
System
Cross border
Relief for
Double
taxation
Tax payment
And refund
System
9. Other features of the Maltese tax system
■ No Thin Cap and CFC rules
■ No withholding tax on dividends, interest and
royalties
■ No specific transfer pricing rules
■ Unlimited carry forward of losses
■ Limited tax on capital gains
■ No capital or wealth taxes
■ No entry and exit taxes
■ Procedure for formal tax rulings and informal system
of Revenue guidance
■ Re domiciliation procedure
96/26/2013
10. Taxation of Maltese companies
■ Maltese companies are subject to a flat tax rate of 35%
■ Malta’s taxation of dividends is based on the full
imputation system, i.e. a full credit of the normal
tax rate of 35%
■ Effective system for relief of double taxation to
companies
■ Tax refunds available to shareholders
106/26/2013
11. Full imputation system of taxation
■ A mechanism to grant relief from economic double
taxation
■ Same profits should not be taxed twice in the hands of
different persons
■ Corporate tax is a prepayment of shareholders’ tax
116/26/2013
12. The full imputation system of taxation
■ Company profits are subject to tax
■ On distribution, these profits are in the hands of a different
person – the shareholder
■ Dividends are essentially the same profits
■ In principle there should not be any further tax on these
profits
126/26/2013
13. The full imputation system of taxation
Company € Shareholder €
Profit before tax 100 Gross dividend 100
Tax at 35% (35) ____
____
Net profit after tax 65 Tax at 35% 35
available for distribution ____ Tax at source (35)
____
-
____
136/26/2013
14. Cross-border relief from double taxation
1. Treaty Relief
2. Commonwealth Relief
3. Unilateral Relief - including a credit system for relief of
underlying tax and
4. Flat-Rate Foreign Tax Credit of 25%.
Overseas income is never subject to double taxation
146/26/2013
15. 63 Double Taxation Treaties in Force as at May 2013
Albania
Australia
Austria
Bahrain
Barbados
Belgium
Bulgaria
Canada
China
Croatia
Cyprus
Czech Rep.
Denmark
Egypt
Estonia
Finland
France
Georgia
Germany
Greece
Guernsey
Hong Kong
Hungary
Iceland
India
Ireland
Isle of Man
Italy
Jersey
Jordan
Korea
Kuwait
Latvia
Lebanon
Libya
Lithuania
Luxembourg
Malaysia
Montenegro
Morocco
Netherlands
Norway
Pakistan
Poland
Portugal
Qatar
Romania
San Marino
Saudi Arabia
Serbia
Singapore
Slovakia
156/26/2013
16. 4 Treaties signed but not yet in force
Israel
Mexico
Russia
Turkey
166/26/2013
17. No outbound tax is withheld on payments of
■ Interest; and
■ Royalties
when paid to non-Maltese residents.
Such income is exempt from Maltese income tax.
No withholding tax on dividends in view of the imputation system
176/26/2013
18. Refundable tax credit system
■ Shareholders of a company registered in Malta are
entitled to claim certain refunds of tax paid by the
company upon the receipt of a dividend distributed by
the company
■ No distinction between local and foreign sourced income
(exceptions)
■ There are 4 types of refunds (6/7, 5/7, 2/3 or 100% of tax
paid by the company)
186/26/2013
19. Practical example of the refundable tax credit system
Malta company €
Profit before tax 1,000
Tax at 35% (350)
_____
650
Distribution of profits (650)
_____
-
_____
Shareholder €
Gross dividend 1,000
_____
Maximum tax 350
Tax at source (350)
_____
-
_____
Refund of tax (6/7) 300
_____
196/26/2013
20. ■ Step 1: Malta Operating
Company receives trading
profits of €100.
■ Step 2: Malta Operating
Company suffers tax at the
corporate rate of 35%.
■ Step 3: Malta Operating
Company effects a
distribution of the net
dividend amounting to €65
to the Malta Holding
Company. The latter pays no
further tax.
Practical example of the refundable tax credit system
206/26/2013
21. ■ Step 4: A refund of 6/7ths
of the tax paid by the Malta
Operating Company may be
claimed at the level of the
Malta Holding Company.
■ Result: Effective post-
refund tax burden of 5%.
■ Holding company does not
pay any tax on dividends
and refunds received
Practical example of the refundable tax credit system
216/26/2013
22. Why is Malta a prime EU holding company location?
■ Access to wide treaty network and EU directives for reduced
withholding tax on interest, dividends and royalties
■ Effective means to structure the ownership of EU and non EU
subsidiaries
■ Full participation exemption on dividends and capital gains
■ No CFC and thin cap rules
■ No withholding tax on outbound payments of interest, dividends
and royalties
■ Tax neutral liquidation of the holding company
226/26/2013
23. Why is Malta a prime EU holding company location?
■ Exemptions from the requirement to prepare consolidated
financial statements at the level of the Malta parent company
■ No exit taxes
■ Possible to migrate the legal seat of the Malta company to a
foreign jurisdiction
■ Low share capital requirements and incorporation is swift
■ Single member companies are possible
■ Low statutory fees
236/26/2013
24. Why is Malta a prime EU holding company location?
■ No tax on capital gains derived from the disposal of shares in a
Maltese company (exceptions property companies)
■ No worth tax or similar tax on capital
■ Exemption from stamp duty
■ Expense deductibility
246/26/2013
25. Malta holding companies – participating holding
An investment constitutes a participating holding when,
amongst other conditions:
■ The Malta Company holds at least 10% of the equity
shares of an overseas company; OR
■ The value of the shareholding exceeds €1,165,000 and
said holding is held for an uninterrupted period of not less
than 183 days.
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26. ■ Where a company elects to pay tax on
its income from a Participating Holding, the
tax paid by the company will be refunded in
full to the shareholder.
■ Refund of tax is calculated on the total tax
paid, that is, inclusive of foreign tax.
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27. Participation Exemption
If the holding is in a company which:
■ is resident or incorporated in the EU; or
■ is subject to any foreign tax of at least 15%; or
■ does not have more than 50% of its income derived from
passive interest or royalties
such a holding will qualify for a participation exemption.
■ Exemption may also be extended if a number of further
conditions are satisfied
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28. Participation Exemption
This means that:
■ Dividends received by the Malta company will be exempt
from Maltese income tax
■ Capital gains derived from the disposal of the holding will be
exempt from Maltese income tax
■ Malta company may opt to be taxed at 35% with full refund
given to the shareholder on distribution of a dividend
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29. Out of Malta
In Malta
Into Malta
Summary of Taxation of Income Flows
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30. MALTA TAX PLANNING IDEAS
■ Malta Holding Company Structures
■ Participation exemption in Malta on qualifying
dividends and capital gains
■ No withholding tax on dividends distributed by
Malta company
■ FP can be resident in a treaty or non-treaty
country and can also be situated in a low tax
jurisdiction
■ Effective 0% Malta tax cost
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32. MALTA TAX PLANNING IDEAS
■ An EXIT ROUTE from the EU
■ NO WHT on dividends paid to Malta from
the EU
■ Dividends received in Malta should be
exempt from tax in Malta under the
participation exemption regime
■ No WHT on outbound interest, royalty and
dividend payments from Malta
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33. MALTA TAX PLANNING IDEAS
■ Malta combined Holding/ Trading Structures
■ Malta 2 subject to Malta tax at 35%
■ Malta 1 receives 6/7ths tax refund from tax
authorities and dividends from Malta 2. These
will not be subject to further tax in Malta in
the hands of Malta 1.
■ Malta 1 distributes dividends to FP. No
withholding tax on payment of dividends.
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34. CONCLUSION - MALTA
■ Robust tax efficient system
■ Stable and safe economy
■ Incentives to do business or hold investments
■ High corporate tax rate but refunds reduce net effective tax
■ Number of tax planning ideas
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35. For further information kindly
contact us:
info@emd.com.mt
+356 2203 0000
MALTA
Stephen Balzan
Tax Partner EMD
LEGAL TAX ADVISORY CORPORATE
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36. DISCLAIMER
This presentation has been prepared for general guidance and for
matter of interest only and does not constitute professional
advice. You should not act upon the information contained in this
presentation without obtaining specific professional advice. No
representation or warranty (express or implied) is given as to the
accuracy and completeness of the information contained in this
presentation, and the firm does not accept any liability and
disclaims all responsibility for the consequences of you or anyone
else acting, or refraining to act, in reliance on the information
contained in this presentation or for any decision based on it.
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