Malta does not operate a specific holding company regime. Accordingly, a Maltese ‘Holding’ Company is a regular company having, as its sole object, the acquisition of participations in other companies. Still, the benefits typically available under such regimes are equally available to Maltese companies in respect of their holding activities.
A Maltese company may be constituted either as a public limited company or as a private limited company.
The minimum share capital for incorporation of a Maltese company is €46,588 for a public limited company and €1.165 for a private limited company.
25% of the issued share capital of a public company must be paid up whilst 20% of the issued share capital of a private company must be paid up.
A Malta company is typically incorporated within 2-3 days.
A company registered in Malta is subject to tax on its worldwide profits at the flat rate of 35%.
Malta operates a full imputation system. As such, dividends distributed by a Maltese company carry a credit in favour of recipient shareholder/s which is equal to the amount of underlying tax paid by the Malta company on the profits out of which the dividend was distributed.
The taxable income of a Maltese company is based on the financial statements of the company (subject to applicable adjustments). Expenses wholly and exclusively incurred in the production of chargeable income are deductible.
Capital gains realised by a Malta company pursuant to a disposal of its shares in a subsidiary would be exempt from Malta tax to the extent that the Malta company’s investment in the subsidiary would represent a ‘participating holding'. A Malta company would have a ‘participating holding’ in a subsidiary company if the following conditions are satisfied:
A. The subsidiary does not own, directly or indirectly, immovable property situated in Malta (or rights over such property); and
B. The shares held by the Malta company in the subsidiary carry at least two of the following rights: (i) a right to votes; and/or (ii) a right to profits available for distribution; and/or (iii) a right to assets available for distribution in the event of a winding up; and
C. At least one of the following 6 additional qualifying criteria are met:
Dividend income accruing to a Malta company from a non-resident subsidiary would be exempt from Malta tax to the extent that the Malta company’s investment in the distributing subsidiary would represent a participating holding (described above) and, additionally, provided that:
Besides the common advantages of a Malta ‘holding company’, additional attractive features of a Maltese company include the following:
Double Tax Treaties
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