Through Legal Notice 188 of 2025, published on 2 September 2025,
the Minister responsible for finance introduced the Final Income
Tax Without Imputation Regulations, 2025 (the
"Regulations") in relation to Article 22B of the Income
Tax Act.
This Legal Notice establishes an optional alternative basis of
taxation in Malta, available to companies as well as to other
persons taxed in the same manner as companies and certain
trusts.
Under the traditional full imputation system, entities are
subject to a 35% corporate tax rate, with shareholders entitled to
claim refunds. By contrast, under the new regime, entities may
elect to be taxed at a final rate of 15% on their chargeable income
in lieu of the imputation system that has long characterised
Malta's corporate tax regime.
