
MALTA COMPANY
EU COMPANY

No withholding tax on outbound
dividends
Tax exemption on income

0% withholding tax based on the PSD

Capital gains tax protection based on
several DTT’s including Denmark,
Italy, Sweden, Germany, Czech
Republic, Poland, Slovenia, Spain,
Portugal, United Kingdom

MALTA COMPANY


LUXEMBOURG HOLDING
COMPANY

No withholding tax on outbound
dividends
Tax exemption on income
0% withholding tax based on the
broad implementation of PSD
Capital gains tax protection based on
DTT

MALTA COMPANY


DUTCH HOLDING
COMPANY

No withholding tax on outbound
dividends
Tax exemption on income
0% withholding tax based on the
broad implementation of PSD
Capital gains tax protection based on
DTT

MALTA COMPANY


GERMAN COMPANY

No withholding tax on outbound
dividends
Licensing or financing activities
Profits subject to 0-6.25% effective tax
0% withholding tax on interest and
royalty payments based on DTT
MALTA COMPANY
Interest
Payment


0-6.25% effective tax on passive
interest income
No transfer pricing documentation
TREATY COUNTRY/ EU
COUNTRY AFFILIATED
DEBTOR


Reduction of WHT based on treaty
Exemption from WHT based on EU
interest and royalty directive
MALTA COMPANY
Royalty
Payment


TREATY COUNTRY/ EU
COUNTRY AFFILIATED
DEBTOR


0-6.25% effective tax on passive
licensing income
No amortisation – IP contributed at
nominal value
Reduction of WHT based on treaty
Exemption from WHT based on EU
interest and royalty directive
MALTA COMPANY
Country A
High tax country

No withholding tax on outbound
dividends

0-5% net effective tax on
trading profits
FOREIGN
SHAREHOLDER

No withholding tax on outbound
dividends

Refund on dividend distribution

Profits subject to net effective
tax of 5% plus gaming tax based
on turnover
MALTA COMPANY
MALTA LICENSED
GAMING COMPANY
SHAREHOLDER

No withholding tax on outbound
dividends

Refund on dividend distribution

Profits subject to net effective
tax of 5%
MALTA COMPANY
MALTA E-COMMERCE
COMPANY
CYPRUS COMPANY
EFFECTIVELY MANAGED
& CONTROLLED
IN MALTA

No withholding tax on outbound
dividends

Effective management and
control in Malta

Company subject to tax on
income arising and on income
remitted to Malta only

Income not subject to tax in Cyprus
OFFSHORE COMPANY
MALTA COMPANY



TREATY COUNTRY/
EU COUNTRY
AFFILIATED DEBTOR


0-6.25% effective tax
No transfer pricing
documentation
No withholding tax on interest
payments
Reduction of withholding tax
based on treaty
Exemption from WHT based on
EU interest and royalty directive
OFFSHORE COMPANY

MALTA COMPANY



TREATY COUNTRY/
EU COUNTRY
AFFILIATED DEBTOR


Owner of IP
0-6.25% effective tax
No transfer pricing
documentation
No withholding tax on royalty
payments
Reduction of withholding tax
based on treaty
Exemption from WHT based on
EU interest and royalty directive



MALTA TRUST

Tax transparent
Income attributable to the trust
is not subject to tax in Malta
Look-through approach –
income directly received by the
beneficiary
Non-residents not subject to tax
other than on income arising in
Malta or the transfer of
immovable property in Malta