Malta, gli accordi fiscali

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Malta è una giurisdizione tanto particolare quanto interessante dal punto di vista fiscale e giuridico. Le società costituite sull’isola hanno un regime di tassazione del tutto peculiare che, in determinati casi, si dimostra davvero interessante. La corporation tax maltese, infatti, ha un impatto del 35% sugli utili netti della società (questo potrebbe non sembrare intessante visto la tutto sommato aliquota elevata). Tuttavia i soci azionisti non maltesi, possono beneficiare di un refund pari a 6/7, 5/7 o addiruttura 100% di imposta quando i dividendi sono distribuiti. Questo fa si che, a livello dell’azionista, la tassazione possa impattare tra il 5 e il 15% a seconda dei casi. Resta tuttavia ben inteso che tale refund di imposta è possibile solo quando l’azionista riceve la distribuzione degli utili. Un’altro aspetto molto interessante è che non vi è alcuna tassa su stacco dividendi, interessi e royalities che vengono pagati ad azionisti non-maltesi.

Suggeriamo sempre ai clienti di comprendere in modo completo come funziona questo sistema di tassazione, prima di decidere se entrare o meno su questo mercato. Infatti il sistema di tassazione maltese sulle società non sempre si adatta a tutte le esigenze imprenditoriali degli investitori non maltesi, e ciò va considerato in fase di setup del proprio business sull’isola. Possiamo assistervi riguardo la strategia da adottare nel dettaglio. Potete cliccare sul link sottostante per scaricare l’elenco degli accordi fiscali in essere con Malta.

Malta accordi fiscali

elenco accordi fiscali in essere (courtesy of MFSA)

 

Country Flag

Country Name

Taxation Treaty Description

 Legal Notice
Albania Double Taxation Relief (Taxes on Income) (Republic of Albania) – Signed on 2 May 2000 LN 122 of 2001
Australia Double Taxation Relief (Taxes on Income) (Australia) – Signed on 9 May 1984 LN 45 of 1985
Austria Double Taxation Relief (Taxes on Income) (Republic of Austria) Order 1981 – Signed on 29 May 1978 LN 130 of 1981
Bahrain Double Taxation Relief (Taxes on Income) (Kingdom of Bahrain) Order, 2012 LN 82 of 2012
Barbados Double Taxation Relief (Taxes on Income) (Barbados) Order, 2002 – Signed on 5 December 2001 LN 249 of 2002
Belgium Double Taxation Relief (Taxes on Income) (Kingdom of Belgium) (Amendment) Order, 2002 – Signed on 28 June 1974 LN 108 of 1976
Belgium Double Taxation Relief (Taxes on Income) (Kingdom of Belgium) (Amendment) Order, 2002 – Supplemenatry Agreement Signed on 23 June 1993 LN 83 of 2003
Bulgaria Double Taxation Relief (Taxes on Income) (People’s Republic of Bulgaria) Order, 1988 – Signed on 23 July 1986 LN 62 of 1988
Canada Double Taxation Relief (Taxes on Income) (Canada) Order, 1988 – Signed on 25 July 1986 LN 12 of 1988
China Double Taxation Relief (Taxes on Income) (People’s Republic of China) Order, 1994 – Signed on 2 February 1993 LN 104 of 1994
China Double Taxation Relief (Taxes on Income) (People’s Republic of China) Order, 2011 – Signed on 23 October 2010 LN 423 of 2011
Croatia Double Taxation Relief (Taxes on Income) (Republic of Croatia) Order, 2000 – Signed on 21 October 1998 LN 71 of 2000
Cyprus Double Taxation Relief (Taxes on Income) (Republic of Cyprus) Order, 1994 – Signed on 22 October 1993 LN 139 of 1994
Czech Republic Double Taxation Relief (Taxes on Income) (Czech Republic) Order, 1997 – Signed on 21 June 1996 LN 228 of 1997
Denmark Double Taxation Relief (Taxes on Income) (Kingdom of Denmark) Order, 1999 – Signed on 30 December 1998 LN 124 of 1999
   Egypt Double Taxation Relief (Taxes on Income) (The Arab Republic of Egypt) Order, 2001 – Signed on 20 February 1999  LN 205/2001
Estonia Double Taxation Relief (Taxes on Income) (The Republic of Estonia) Order, 2003 – Signed on 3 May 2001 LN 114 of 2003
Finland Double Taxation Relief (Taxes on Income) (Republic of Finland) Order, 1981 – Signed on 24 March 1975 LN 109 of 1981
Finland Double Taxation Relief Income with the Republic of Finland Order, 2001 – Signed on 30 October 2000 LN 34 of 2002
France Double Taxation Relief (Taxes on Income) (Republic of France) Order, 1983 – Signed on 5 July 1977 LN 5 of 1983
France Double Taxation Relief (Taxes on Income) (Republic of France) (Amendment) Order, 1998 – Protocol Signed on 8 July 1994 LN 238 of 1998
France Double Taxation Relief (Taxes on Income) (Republic of France) (Amendment) Order, 2008 – Protocol Signed on 29th August 2008. LN 329 of 2010
Georgia Agreement between Malta and TheGovernment of Georgia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital – signed on 23 October 2009 LN 65 of 2010
Germany Double Taxation Relief (Taxes on Income) (Federal Republic of Germany) Order, 2002 – Signed on 8 March 2001 LN 254 of 2002
Germany Double Taxation Relief on Taxes on Income withthe Federal Republic of Germany (Amendment) Order, 2011, Signed on 17 June 2010 LN 383 of 2011
Greece Double Taxation Relief (Taxes on Income) (Hellenic Republic) Order, 2008 – Signed on 13 October 2006 LN 268 of 2008
  Guernsey Double Taxation Relief (Taxes on Income) (The States of Guernsey) Order, 2013 – Signed on 12 March 2012 LN 117 of 2013
  Hong Kong Double Taxation Relief (Taxes on Income) (The Hong Kong Special Administrative Region of the People’s Republic of China) Order, 2012 LN 321 of 2012
Hungary Double Taxation Relief (Taxes on Income) (Republic of Hungary) Order, 1994 – Signed on 6 August 1991 LN 75 of 1994
Iceland Double Taxation Relief (Taxes on Income) (Iceland) Order, 2006 – Signed on 23 September 2004 LN 261 of 2006
India Double Taxation Relief (Taxes on Income) (Republic of India) Order, 1995 – Signed on 8 September 1994 LN 46 of 1995
Ireland Convention between Malta and Ireland for the avoidance of Double Taxation and the Prevention of Fiscal evasion with respect to taxes on income – Signed 14 November 2008 LN 62 of 2009
Isle of Man Double Taxation Relief (Taxes on Income) (The Isle of Man) Order – signed on 23 Octber 2010 LN 162 of 2010
Italy Double Taxation Relief, (Taxes on Income) (Republic of Italy)Order, 1986 LN. 31 of 1986
Italy Double Taxation Relief, (Taxes on Income) (Republic of Italy) Order, 1986 – Signed on 16 July 1981 LN 41 of 2011
Jersey Double Taxation Relief (Taxes on Income) (Jersey) Order, 2010 LN 432 of 2010
Jordan Double Taxation Relief (Taxes on Income) (The Hashemite Kingdom of Jordan) Order, 2010 LN 501 of 2010
Korea Double Taxation Relief (Taxes on Income) (Republic of Korea) Order, 1999 – Signed on 25 March 1997 LN 18 of 1999
Kuwait Double Taxation Relief (Taxes on Income) (State of Kuwait) Order, 2004 – Signed on 24 July 2002 LN 349 of 2004
Latvia Double Taxation Relief (Taxes on Income) (Republic of Latvia) Order, 2001 – Signed on 22 May 2000 LN 89 of 2001
Lebanon Double Taxation Relief (Taxes on Income) (Republic of Lebanon) Order, 2000 – Signed on 23 February 1999 LN 119 of 2000
Lebanon Protocol amending the convention between Malta and the Republic ofLebanon with respect to taxes on income- signed on 16 April 2010 LN 242 of 2010
Libya Double Taxation Relief (Taxes on Income) (Libyan Arab Republic) Order, 1973 – Signed on 5 October 1972 – Shall cease to have effect with respect to income derived during the taxable years beginning on or after 1 January 2011 LN 7 of 1973
Libya Double Taxation Relief (Taxes on Income) (Libyan Arab Republic) (Amendment) Order, 1996 – Protocol Signed on 28 April 1995 LN 201 of 1996
Libya Double Taxation Relief (Taxes on Income) (The Great Socialist People’s Libyan Arab Jamahiriya) Order, 2010 – Signed on 28th December 2008 – Shall have effect with respect to income derived during the taxable years beginning on or after 1 January 2011 LN 328 of 2010
Lithuania Double Taxation Relief (Taxes on Income) (Republic of Lithuania) Order, 2004Signed on 17 May 2001 LN 337 of 2004
Luxembourg Double Taxation Relief (Taxes on Income) (Grand Duchy of Luxembourg) Order, 1996 – Signed on 29 April 1994 LN 65 of 1996
Malaysia Double Taxation Relief (Taxes on Income) (Malaysia) Order, 1986 – Signed on 3 October 1995 LN 281 of 2002
Montenegro Convention between Malta and Montenegro for the avoidance of Double Taxation with respect to taxes on income – Signed 4 November 2008 LN 343 of 2009
Morocco Double Taxation Relief Taxes on Income with the Kingdom of Marocco Order, 2007 – Signed 26  October 2001 LN 189 of 2007
Netherlands Double Taxation Relief (Taxes on Income) (Kingdom of the Netherlands) Order, 1980 – Signed on 18 May 1977 LN 90 of 1980
Netherlands Double Taxation Relief (Taxes on Income) (Kingdom of the Netherlands) (Amendment) Order, 1999 – Protocol Signed on 18 July 1995 LN 146 of 1999
Norway Double Taxation Relief (Taxes on Income) (Kingdom of Norway) Order, 1979 – Signed on 2 June 1975 LN 35 of 1979
  Norway Double Taxation Relief (Taxes on Income) (The Kingdom of Norway) Order, 2013 – signed on 30 March 2012 LN 118 of 2013
Pakistan Double Taxation Relief (Taxes on Income) (Islamic Republic of Pakistan) Order, 1980 – Signed on 8 October 1975 LN 54 of 1980
Poland Double Taxation Relief (Taxes on Income) (Republic of Poland) Order, 1995 – Signed on 7 January 1994 LN 28 of 1995
Poland Double Taxation Relief (Taxes on Income) (Republic of Poland)(Amendment) Order, 2012 – Signed on 6 April 2011 LN 14 of 2012
Portugal Double Taxation Relief (Taxes on Income) (Portuguese Republic) Order, 2002 – Signed on 26 January 2001 LN 105 of
2002
Qatar Agreement between Malta and The State of Qatar for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on IncomeAvoidance – signed on 26 August 2010 LN 69 of 2010
Romania Double Taxation Relief (Taxes on Income) (Romania) Order, 1997 – Signed on 30 November 1995 LN 65 of 1997
San Marino Double Taxation Relief (Taxes on Income) (The Republic of San Marino) Order, 2006 – Signed on 3 May 2005 LN 270 of 2006
San Marino Protocol amending the convention between Malta and the Republic of San Marino with respect to taxes on income – signed on 10 September 2009 LN 192 of 2010
  Saudi Arabia Convention between the Government of Malta and the Government of the Kingdom of Saudi Arabia for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income – signed on 4 January 2012 LN 25 of 2013
Serbia Double Taxation Relief (Taxes on Income) (The Republic of Serbia) LN 431 of 2010
Singapore Double Taxation Relief (Taxes on Income) (Republic of Singapore) Order, 2008 – Signed on 29 February 2008 LN 194 of 2008
Slovakia Double Taxation Relief (Taxes on Income) (Slovak Republic) Order, 2001 – Signed on 7 September 1999 LN 1 of 2001
Slovenia Double Taxation Relief (Taxes on Income) (The Republic of Slovenia) Order, 2003 – Signed on 8 October 2002 LN 145 of 2003
South Africa Double Taxation Relief (Taxes on Income) (South Africa) Order, 1998 – Signed on 16 May 1997 LN 89 of 1998
Spain Double Taxation Relief on Taxes on Income with the Kingdom of Spain Order, 2006 – Signed on 8 November 2005 LN 234 of 2006
Sweden Double Taxation Relief (Taxes on Income) (The Kingdom of Sweden) Order, 1996 – Signed on 9 October 1995 LN 104 of 1996
Switzerland Double Taxation Relief (Ships and Aircraft) (Swiss Federation) Order, 1988 – Signed on 30 March 1987 LN 31 of 1988
  Switzerland Double Taxation Relief (Taxes on Income) (The Swiss Confederation) Order, 2012 LN 322 of 2012
Syria Convention between Malta and The Syrian Arab Republic for the avoidance of Double Taxation and the Prevention of Fiscal evasion with respect to taxes on income – Signed on 22 February 1999 LN 246 of 2001
Tunisia Convention between Malta and Tunisia for the avoidance of Double Taxation and the Prevention of Fiscal evasion with respect to taxes on income – Signed on 31 May 2000 LN 225 of 2002
United Arab Emirates Double Taxation Relief (Taxes on Income) (United Arab Emirates) Order, 2009 – Signed on 13 March 2006  LN 99 of 2009
United Kingdom Double Taxation Relief (Taxes on Income) (United Kingdom of Great Britain and Northern Ireland) Order, 1995 – Signed on 12 May 1994 LN 105 of
1995
United States of America Double Taxation Relief (Ships and Aircraft) (United States of America) Order, 1997 – Signed on 11 March 1997 (Ships and Aircraft) LN 230 of 1997
United States of America  Double Taxation Relief (Taxes on Income) (United States of America) Order, 2010 – Signed on 8 August 2008  LN 560 of 2010
  Uruguay Double Taxation Relief (Taxes on Income) (The Oriental Republic of Uruguay) Order, 2013 – signed on 11 March 2011 LN 119 of 2013

 

 

Country Flag Country Name Treaties signed but not in force
  Belgium Protocol amending the agreement between the State of Malta and the Kingdom of Belgium for the avoidance of double taxation and the prevention of fiscal evasion,and the protocol signed at Brussels on 28 June 1974, as amended by the supplementary agreement signed at Bruseels on 23 June 1993 – signed on 19 January 2010
  Israel Convention between the Government of Malta and the Government of the State of Israel for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income – signed on 28 July 2011
Luxembourg Protocol to amend the convention between Malta and the grand duchy of Luxembourg for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, signed at Luxembourg on 29 April 1994. The Protocol was signed on 30 November 2011.
  Mexico Convention between the United Mexican States and Malta for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income – signed on 17 December 2012.
  South Africa Protocol amending the agreement between the Government of Malta and the Government of the Republic of South Africa  for the avoidance  of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at rome on 16 may 1997 – signed on 24 August 2012
  Turkey Agreement between the Republic of Malta and the Republic of Turkey for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income – signed on14 July 2011

 

Country Flag Country Name Tax Information Exchange Agreements – in force Legal Notice
  Bahamas Agreement between the Government of Malta and the Government of the Commonwealth of the Bahamas for the exchange of information relating to tax matters – signed on 18 January 2012 LN 26 of 2013
  Bermuda Exchange of Information (Tax Matters) (Bermuda) Order, 2013 – signed on 24 November 2011 LN 120 of 2013
  Gibraltar Agreement between the Government of Malta and the Government of Gibraltar for the exchange of information relating to tax matters – signed on 24 January 2012 LN 208 of 2012