ARTICLE · 01 DECEMBER 2022

Malta Introduces Formal Transfer Pricing Requirements

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On 18th November 2022 Malta has published Legal Notice 284 of 2022 hereby implementing Transfer Pricing Rules in to legislation.

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Malcolm Ferrante

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On 18^th November 2022 Malta has published Legal Notice 284 of 2022 hereby implementing Transfer Pricing Rules in to legislation.

The Transfer Pricing Rules shall come in to effect as from 1^st January 2024 in relation to any arrangement entered into on or after that date, and for those arrangements entered into before that date, the Transfer Pricing Rules shall apply to those arrangements that are materially altered on or after that date.

The rules shall apply to cross border arrangements carried out between associated parties. Associated entities are defined as having 50% or more of common direct or indirect participation rights in large multinational groups in scope for Country-by-Country reporting or 75% in the case of large multinationals which are excluded from such reporting, however, such rules shall not apply to micro, small or medium-sized enterprises fulfilling the criteria laid down in Annex I of the Commission regulation (EU) 651/2014.

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