ARTICLE · 18 SEPTEMBER 2025

Malta Introduces Final Income Tax Without Imputation Regulations 2025

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The Government of Malta has published Legal Notice 188 of 2025 – the Final Income Tax Without Imputation Regulations, 2025, in relation to Article 22B of the Income Tax Act. Such legal notice provides companies and certain trusts with the option to elect for a final tax rate in lieu of the imputation system, that has long characterised Malta's corporate tax regime.

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Audrey Azzopardi

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The Government of Malta has published Legal Notice 188 of 2025 – the Final Income Tax Without Imputation Regulations, 2025, in relation to Article 22B of the Income Tax Act. Such legal notice provides companies and certain trusts with the option to elect for a final tax rate in lieu of the imputation system, that has long characterised Malta's corporate tax regime.

Key Features of the Regulation

Entities may choose to be subject to tax either under the existing provisions of the Income Tax Act, or at a final income tax rate of 15% on chargeable income. Entities which opt to be subject to the final tax rate of 15% must formally notify the Commissioner for Tax and Customs.

Such election may be applied to income derived in the fiscal year preceding the year of assessment 2025 and subsequent years.

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