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GloBE Country Guide: Malta

Summary

Status Enacted Regulation
LawLegal 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 DateAccounting periods beginning on or after December 31, 2023
IIRArticle 50 Postponement
UTPRArticle 50 Postponement
QDMTTNo
Filing DeadlinesStandard Art. 50 Filing
Safe HarboursNo

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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