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An
International Tax Unit has been established to deal with all international
tax matters and to provide rulings in advance in areas where there might
otherwise be uncertainty or fear of infringing Maltese anti-avoidance legislation.
In
this way, the fiscal implications of investing in or through Malta, or
of setting up a base in Malta, or of any particular international transaction
will be made clear from
the outset. Rulings
will be available to confirm the tax position on the following particular
issues:
-
the position regarding
the general anti-avoidance provisions contained in section 51 of the Income
Tax Act;
-
whether a shareholding
is in the course or furtherance of the shareholder's business for the purposes
of a participating holding (see Section 3.3);
-
the tax treatment of
any particular financial instrument;
-
the tax treatment of
any transaction which involves international business;
-
whether a company qualifies
as an international trading company (see Section 3.4)
These
rulings guarantee the tax position for a period of five years and may be
renewed for a further five year period. They will also survive any
changes of legislation for a period of two years after the entry into force
of the new law. |
Malta
as a Tax Friendly Jurisdiction
