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Malta: What Are The International Tax Planning Opportunities? Part 1

400 300 Ciantar Associates

expense report

In the first of a 3-part introduction to Malta’s tax system, we look briefly at its main advantages and benefits and show you why Malta is fast becoming a significantly important financial centre within the European Union.

A long history of fiscal and investment incentives for foreigners wishing to set up shop in Malta have led to a very attractive package for both investors as well as for non-residents wishing to use Malta in their international tax planning structures.
The Main Advantages of Malta’s Tax System
  • Net tax payable of 5% on company profits
  • Nil tax payable on incoming dividends from subsidiaries situated outside Malta (subject to certain conditions)
  • Possibility to opt to be taxed at 35% on incoming dividends and subsequently apply for a full refund or 6/7 refund on the Malta tax paid (i.e. 5% net tax). This might be beneficial in cases where the foreign shareholders would need to show that income has suffered tax
  • Net tax payable of 10% on passive income received from outside Malta (such as interest and royalties)
  • A Maltese Company can act as both a holding company and a trading company with no negative tax consequences, thus eliminating the need to open separate companies
  • A branch of a non-resident company carrying out activities in Malta will be treated in the same way as a resident company with resultant tax planning opportunities, and benefitting from the same net tax rate of 5% as companies
  • No Withholding taxes on outbound dividends, interest or royalties
  • Three or more tier Malta companies are possible
  • Relief on tax suffered abroad on incoming dividends possible up to full amount of Malta tax payable (35%) (if such dividend does not satisfy the conditions for exemption mentioned above)
  • Possibility to claim relief on Malta tax payable on income received from outside Malta, even if such income has not been subject to tax abroad or if such income has suffered tax at a lower rate
  • Full exemption on stamp duty and capital gains upon the transfer of shares between non-residents (subject to certain conditions)
  • Possibility of reorganisation relief, wherein a company can be amalgamated, split, or merged without losing any accumulated tax losses (in fact, tax losses can be surrendered or claimed within a group and set off against any other type of income and such claimed losses can be carried forward indefinitely)
  • All costs incurred in the production of the income is allowed as a tax deductible expense, there are no disallowed expenses (except for formation expenses)
  • Ability to hold shares under fiduciary (nominee). In order to hold shares under fiduciary a fiduciary agent must be a specially licensed company. Such company is bound by law NOT to reveal the identity of the ultimate beneficiary owners of a company to ANY party including the financial regulatory body (Malta Financial Service Authority) Indeed the only authority who has the right to ask for this information are the Courts of Malta and then only in cases of serious suspicion of fraud or money laundering
  • Malta currently has over 50 double taxation agreements in place including with all EU countries and with the US. Moreover the number is increasing yearly.
Other Benefits:
  • Member of the EU
  • Member of the Euro Zone
  • A sound banking system with representatives of some major banks like HSBC and Lombard Plc. The banking sector in Malta was almost completely unaffected by the world economic crisis due mainly to their low exposure to international finance
  • Maltese legislation conforms fully to EU law, EU code of conduct of business and abides to the Organization for Economic Co-operation and Development (OECD) standards
  • Possibility of redomiciliation of companies from anywhere in the world as long as such redomiciliation is allowed in the jurisdiction of the country of incorporation of the company and the country is not a black-listed country
  • English being one of the two official languages
  • A democratic and stable government
  • A well-established legal system based on UK law
  • A professional English speaking work force with a European mentality
  • A relatively low cost base
  • One of the best IT infrastructures in the EU
  • Good flight connections to all major EU cities.
Parts 2 and 3 of this series will delve deeper in to the features and benefits of Malta’s tax system, but for now, if you would like any more information on why Malta could be the jurisdiction of choice for your clients’ tax planning opportunities, please do not hesitate to get in touch.

The Isle of Man as a Wealth Management Centre

1024 576 Wealth Management Services

Peel Castle

Many readers may be familiar with the Isle of Man as a centre for motor-racing i.e. the famous ‘TT’ races or Manx Kippers! You may even be familiar with its Loaghtan sheep or award winning cheeses but how many of you will realise that the Isle of Man is one of the top 5 centres for space commerce or that it has a thriving eCommerce and eGaming industry or recognise it as a top centre for Wealth Management?

Well, it is pleasing to be able to say that, while the Island was relatively late into the financial services boom of the middle and late 20th Century – seeing the benefits of such only shortly before the creation of the digital world that we now know, it’s relatively recent development has had a significant advantage: the Island did not base its growth on an ‘old world’ economic model but took some inspired decisions early on in the age of the digital evolution or, for many of us, a digital ‘revolution’ i.e. the 1990s and 2000s, that have provided a sound, leading-edge platform for much commercial opportunity and wealth creation & management.

The Isle of Man has benefited by virtue of needing to differentiate itself from the other financial centres that grew up in the 1960s, 70s and 80s. As a UK Crown Dependency, located just off the North West coast of England, it has benefitted from the physical location as the closest Crown Dependency to the City of London and the UK finance sector and has been a conduit of much business to the United Kingdom, from listings on the Stock Exchange, to investment related undertakings such as collective investments or property purchases and commercial undertakings. However, merely replicating what the other finance centres did was not likely to provide long term growth opportunities on a sustainable basis and that was certainly evidenced when we saw the fallout from the recent Great Recession. By identifying some (niche) areas where we could punch above our weight, the Island has enabled real value-added economic development and opportunities for entrepreneurs and professional support services alike.

With a physical location in the centre of the British Isles, occupying an area of c500 square kilometres with a population of only 85,000, the Island is well positioned to provide a secure and accessible location from where we can act as a conduit for investment and business into and within the United Kingdom and the European Union, and, for international trade between Asia and North America. Being part of the ‘Common Purse’ arrangement with the UK enables VAT registration for single point of entry to the EU as a whole. Having significant Ship and Aircraft registers, Space/Satellite licensing ability, and, having an extraordinarily large-capacity and robust digital infrastructure with multiple access points allows the Island to offer the latest IT ‘platform’ to commercial operators, including the eGaming sector.

office site

Alongside the ‘digital’ platform i.e. IT and logistics stands the intellectual property opportunities that we can offer clients. Whether UK entrepreneurs wishing to engage in international commerce, international businesses wishing to trade within the European Union, wealthy individuals and families wishing to ensure a lasting wealth legacy (whether for their families or through charitable foundations etc.), the Isle of Man has a wealth of experienced professionals who can advise upon and structure their clients financial and business requirements, from the simplest to the most complex needs. The professional services sector has been dealing with wealthy individuals, families and corporate businesses for decades and the Island’s links with The City of London has ensured that our connections, knowledge and experience spans all areas of wealth creation and retention, whether physical property, in terms of homes, yachts, aeroplanes, intellectual property, in terms of copyright ownership etc, or the areas of family trusts, foundations and other structuring needs or (possibly) more mundane matters such as pensions and financial planning.

The Island has had to be nimble in its approach and has benefitted from a government that has been both proactive and supportive of business and wealth creation, whilst ensuring best practice in terms of adoption and adherence to international legal and taxation standards and professional expectations.

Our door is open to all-comers, large and small, mainstream and niche. We merely seek to offer professional solutions and adopt best practice in fulfilling our clients’ worthy and legitimate needs.

Whatever your financial or business interests and requirements, do take a little time to enquire how we may be able to assist you in your endeavours and see what we may be able to achieve together.

Wilton Wealth Management is an independent team of highly skilled financial advisers. Our fee based planners are experienced in all aspects of advanced wealth management, analysing complex situations and implementing solutions globally. They manage the financial affairs of a range of clients from professionals to individuals with significant family wealth.

The team will work with you to understand your lifestyle, goals, timeframes and financial requirements. Only then will they put a strategy in place to help you to achieve your overall objectives.

We work hard to create long-term relationships. Our ethos is to provide a service that is transparent and focused on tangible outcomes. We will meet you on a regular basis to track your progress and review your planning. If your goals change, as they often do, we will work with you to ensure the strategy changes as well.