Key facts
| Item | Rate / rule |
|---|---|
| Statutory corporate tax | 35% |
| Shareholder refund on distributed trading profit | 6/7 of the tax → ~5% effective |
| Refund on passive income | 5/7 or 2/3 → ~10–11.7% effective |
| Dividend withholding tax | 0% |
| Optional flat tax (FITWI, since Sept 2025) | 15% final, no refund, binding 5 years |
| Statutory audit | Every company |
The mechanics
A Maltese company pays a flat 35% on its profit. When it distributes a dividend, two things happen. First, under full imputation the dividend carries a credit for the tax the company already paid, so the shareholder owes no further Maltese tax. Second, the shareholder claims a refund of the tax - 6/7 of it on trading income, which turns €35 of tax on €100 of profit into €5. Passive interest and royalties earn a 5/7 refund, and profit that used double-tax relief earns 2/3.[1][2]
The refund goes to the shareholder, not the company. In practice owners hold the trading company through a second Maltese (or foreign) holding company, so the refund lands at the holding level as corporate money rather than as personal income - the classic “two-tier” Malta structure.
The 15% alternative (FITWI)
Since September 2025 a company may instead elect a 15% final income tax with no refund - the FITWI regime, binding for at least five years. It trades a lower headline burden for simplicity: no refund claims, no waiting, and alignment with the 15% global minimum tax that large groups face anyway.[1][2]
The catch
The 5% is genuine, but it is not automatic. Refunds take time and paperwork, and every Maltese company, whatever its size, must file audited financial statements. If you run the company from another country, that country can treat it as tax-resident there under place-of-effective-management rules, and controlled-foreign-company rules can attribute low-taxed profit to the parent. For groups above €750m of revenue, the 15% Pillar Two minimum makes the 6/7 refund irrelevant.[3][4]
よくある質問
Is Malta’s 5% effective tax rate legal?
Yes - the refund is written into Malta’s Income Tax Act and operates openly through the Commissioner for Tax and Customs. What can fail is the cross-border side: residency, substance and CFC rules in the owner’s country.
Do shareholders pay tax on the Maltese dividend?
Not in Malta: full imputation credits the company’s tax against the shareholder’s, and there is no dividend withholding. A shareholder resident elsewhere pays whatever their own country charges on foreign dividends.
Why does Malta keep a 35% headline rate at all?
The imputation system predates EU membership and survived accession review. The high headline rate with refunds preserved Malta’s treaty network and personal-tax integration while keeping the effective burden on distributed business profit low.
国境を越えた結果は、税務上の居住地、CFC（タックス・ヘイブン対策）税制、および実態（サブスタンス）によって異なります。机上のストラクチャーだけでは不十分です。以下の免責事項をご覧ください。
情報源
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