Malta is known for its well-established legal regime regulating
Protected Cell Companies (PCCs), and the benefits of a PCC have
seen ongoing creation of cells within PCCs in Malta as well as in
other domiciles.
As the PCC, together with any protected cells which have been
created constitute a single legal person, the PCC core takes on
responsibility for the management of the overall legal entity,
including compliance. This has many benefits for the individual
cell owners but can bring some challenges for the core.
Tax legislation regularly predates multinational insurance
programmes, let alone the creation of more sophisticated insurance
vehicles such as a PCC. In addition, the traditional, yet
increasing, demands of the tax authorities for the reporting and
settlement of insurance premium taxes (IPT) and parafiscal charges
present challenges in the consolidation of a diverse portfolio of
risks and stakeholders, with the core responsible for compliance of
risks