GloBE Country Guide: Malta

Summary

Status	Enacted Regulation
Law	Legal Notice 32 of 2024 of February 20, 2024 On April 17, 2025, Act No. IX of 2025 was published in the Official Gazette. This includes a new Section 22B in the Income Tax Act to provide that rules will be issued to provide for an elective tax (likely to give Pillar Two in-scope companies the option to subject their profits to the elective tax in Malta to ensure that no top-up tax is due elsewhere).
Effective Date	Accounting periods beginning on or after December 31, 2023
IIR	Article 50 Postponement
UTPR	Article 50 Postponement
QDMTT	No
Filing Deadlines	Standard Art. 50 Filing
Safe Harbours	No

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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