• Ancillary matters

(i) Non-residents 

Non-residents, provided they are not owned by, controlled by, or acting on behalf of, a resident of Malta, and provided they are not otherwise operating in Malta through a permanent establishment, are exempt from Maltese tax on the following: 

• all interest and royalties received from Malta; and
• the disposal of shares or securities in Maltese companies and units in a collective investment scheme.

All documents relating to licensed activities under the Investment Services Act will be exempt from transfer duty. 

(iii) Incorporation as a test of residence 

The test of residence for tax purposes will be extended to any company incorporated in Malta, irrespective of where it has its seat of management. 

All companies registered in Malta after 1st July 1994 are considered to be resident in Malta while all companies incorporated before this date have become resident for tax purposes as from 1st January 1995.