• 20 Years
    experience
    More than 20 years experience in handling international business
    from Malta and a well structured powerful network not limited only
    to this Mediterranean Island but also across North Africa, the Middle East,
    Europe, Switzerland and Asia, makes us a competent and serious partner.
  • Network
    of specialists
    Our expertise guarantees your sustainable business development and we will support you personally
    in all questions related to the set up and management of your Maltese company or your
    international company structure.
  • We make your goals ours !
    Through an intensive dialog we develop solutions together for the best
    possible ways to protect your private or business income in the long term,
    find new markets or optimize your supply chain.
  • We grow with you
    We are looking forward towards a mutually beneficial business
    relationship which should result in easier administration of
    your Maltese business and an efficient cost structure within
    your international setup.

Maltese Holding Companies

Generally there is no distinction between a holding company and a trading or active company, when it comes to taxation in Malta. All Maltese companies pay 35% tax on their profits, but non resident shareholders can claim a tax refund of the following proportions under certain conditions:

6/7th of the tax paid by the Maltese company (except on profits of sale of immovable property in Malta or profits who have been taxed at source) effective tax rate = 5%

5/7 of the tax paid by the Maltese company on profits that consist passive interest or royalties, effective tax rate = 10%

2/3 of tax paid by the Maltese company on profits that have been already claimed relief for double taxation

100% refund on the tax on profits of the Maltese company that are generated from a “participating Holding

This full refund allows the Malta Holding Company to be a very tax efficient vehicle in international tax planning. Maltese Holdings are excellent gateways into or outside the European Union. No withholding tax on dividends, interest, or royalty payments, no capital duties or wealth tax are imposed, not even on disposal of assets and shares of the Maltese company, provided no Maltese immovable property involved. Non resident shareholders of active Maltese Limiteds often opt for a Maltese Holding, to benefit from the exemption rule, as they can keep the dividends and profits outside their residence countries. Inside Europe, the parent subsidiary rules are fully applied. Maltese Holdings are not precluded from carrying out some non holding activities and provide a maximum of flexibility to create cost efficient company structure solutions. Certain compliance requirements are to be met to qualify as a “Participating Holding “ in order to benefit from the tax exemption inside and outside the EU:

A minimum shareholding requirement of 10% of the equity shares or

      A minimum investment in the company of € 1.164.000.- which is held uninterrupted for at least 6 months, or

The right for the Maltese company either to call for or aquire the balance of the shares not held thereby or

Or the entitlement of the Malta Company to refuse a proposed disposal, redemption or cancellation of all the equity shares not held by it, or

The entitlement of the Malta company to sit on the board or to appoint a person to sit on the board as a director, or

That the shares in the company are held for the furtherance of the malta companies own business, provided that there is the shareholding does not represent stock in trade

Under certain conditions even dividends from non European resident companies are exempt

They are subject to foreign tax  of 15% or more, or

They generate less than 50% of their income from interests and royalties or other passive income

If this does not apply then the company I not supposed to receive more than 50% of its income from portfolio investments and pays foreign tax more than 5%

Since a number of years a lot of well known international Companies are using Maltese Holding company structures to optimize their cash flow and tax burden, and have made very positive experiences. Sounds interesting ? Us, at SSCI would like to support you with our experience and knowledge to make the right decisions on your future sustainable, international company structure.

We are looking forward to hear from you.