Corporate Tax

Resident non-Domiciled Companies

Maltese law provides for the possibility of companies being incorporated outside Malta but managed and controlled here in Malta (which in turn are to be deemed fiscally resident in Malta) to be taxed only on a source and on remittance basis. This means that such company will only be taxed in the following instances (obviously when Maltese tax triggers in, the tax refund possibilities outlined above would still be possible):

  • on income and capital gains arising in Malta


  • on foreign income (excluding capital gains) which are remitted into a Maltese bank account

The use of resident non-domiciled companies could be very useful particularly for the following activities:

  • for companies with a considerable cash balance for investment purposes
  • for loan and financing operations (under Maltese legislation no transfer pricing regulations exist with respect to inter-company loans)
  • for companies deriving income from royalties


Case Studies


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