Malta

A company incorporated in Malta is considered as both domiciled and resident in Malta and is consequently taxable on a worldwide basis. A non-Maltese incorporated company that is resident in Malta through management and control is subject to Maltese tax on income arising in Malta and on income received in/remitted to Malta.

Companies are subject to income tax at a flat rate of 35%. There is no corporate tax structure separate from income tax.

Final Income Tax Without Imputation

On 2 September 2025, the Final Income Tax Without Imputation Regulations (“FITWI Regulations”) were published, pursuant to which Maltese entities may elect to apply a rate of tax of 15% on their chargeable income calculated on the basis of the standard Maltese income tax rules. Entities include companies and bodies of persons that elect to be treated as a company for Maltese income tax purposes, as well as entities deemed to be companies in terms of the Maltese Income Tax Act and trusts that elect to be treated as companies.

 Where an entity opts for the said 15% tax rate , the entity’s chargeable income shall not include:

1. Dividends received from profits that are not allocated to the final tax account of another company registered in Malta; and
2.  Income that has been subject to tax at a final rate of tax in terms of the Income Tax Act and, save for the provisions of the FITWI Regulations, is allocated to the final tax account.

Entities who intend to opt for the 15% tax rate as set out in the FITWI Regulations may opt to do so in respect of income accruing to or derived in the fiscal year preceding the year of assessment 2025 and subsequent years. Where entities opt into the 15% rate, the mechanism set out in the FITWI Regulations shall apply for at least five consecutive years, starting from the beginning of the first year of assessment from when the entity opts to apply the 15% rate. Therefore, once an entity opts in, it would be unable to opt out before the expiry of the said five-year period.

The tax charged in accordance with the FITWI Regulations is a final tax, and shall not be available as a credit or set off against the tax liability of any individual or entity, or as a refund to any person.

Petroleum profits tax

Petroleum profits tax is levied as income tax with similar deductions being allowed in respect of incurred expenditure. In the case of a Production Sharing Contract signed after 1 January 1996, any petroleum profits are taxed at the standard corporate tax rate of 35%. However, all other petroleum profits are subject to a 50% tax rate.

Insurance profits tax

Insurance profits tax is levied as income tax and subject to the normal standard tax rate of 35% as other corporate profits; however, the manner in which such profits are ascertained is subject to a number of detailed rules that take into account the special nature of the insurance industry. In the case of non-resident companies, the computation is applied with reference only to business carried on in or from Malta.

Recently introduced rules on the taxation of insurance businesses adopting IFRS 17 came into effect from the year of assessment 2024 for accounting periods starting on or after 1 January 2023, which apply to insurers deriving gains or profits from the business of insurance. The rules (i) regulate the determination of total income based on adjusted profit before tax; (ii) regulate the adoption gains or losses arising from the implementation of IFRS 17; and (iii) provide for an irrevocable option for insurers to spread the tax payment on the adoption gains equally over a maximum period of five consecutive years, subject to an election made by the insurer.

Shipping profits tax

A tonnage tax system is applicable under Maltese law. Such regime covers profits from shipping activities as defined under the applicable regulations that are derived by qualifying Maltese-flagged and EU/European Economic Area (EEA) vessels as well as non-EU/EEA vessels satisfying certain additional rules. Furthermore, qualifying ship management activities are also entitled to the tonnage tax system.

The Maltese tonnage tax regulations allow the exemption of certain shipping income from being charged under income tax. These regulations provide that, subject to the fulfilment of certain conditions, which conditions are modelled on the EU Community Guidelines on state aid to maritime transport, and the full payment of all relevant tonnage taxes by a shipping organisation, a shipping organisation shall not be charged further income tax on the income derived from shipping activities. Income derived from ship management activities may also qualify for the tonnage tax exemption. Furthermore, any further tax derived from income or profit gained from the sale or other transfer of a tonnage tax ship, which ship had been acquired and sold whilst under the tonnage tax system, or from the disposal of any rights to acquire a ship, which when delivered or completed would qualify as a tonnage tax ship, would be exempt.