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Malta as a Tax Friendly Jurisdiction
  • International Trading Companies
A Maltese registered company whose objects are restricted to trading activities of an international nature as defined in the Income Tax Act may be classified as an "International Trading Company".  There are special provisions in the Act that apply to this type of company, the most important of which are: 
  • a company may request the Inland Revenue to confirm by means of an advance revenue ruling its status as an International Trading Company;
  • the company is taxed at the normal company rate of tax which is currently 35%.
Upon a receipt of a dividend from an International Trading Company, non-resident shareholders and Maltese resident companies wholly owned by non-residents are: 
 
  • taxed at a flat rate of 27.5% on the gross amount of the dividend and are credited with the amount of tax paid by the company on the profits out of which the dividend was paid.
  • entitled to a refund under the provisions of the Income Tax Management Act of two-thirds of the Malta tax paid by the company on the same profits.  This refund is payable by the Revenue not later than the fourteenth day following the end of the month in which the refund becomes due.
The following example illustrates how the provisions relating to International Trading Companies work in practice. 

International Trading Company 
 
Chargeable Income
1000
Less: Company income tax at 35%
350
3550
Profit after taxation available for distribution
650
Non resident shareholder or 
Maltese company wholly owned be non-residents
Net divident received from international trading company
650
Add: Tax paid by international trading company
(full imputation system)
350
Chargeable income 1000
Tax thereon at 27.5%
275
Credit received by shareholder for tax paid by company
(350)
Refund to shareholder at assessment stage
75
Further refund of2/3 of the Malta tax paid by the company
233