On 20 February 2024, Malta enacted the relevant provisions of
the EU Minimum Tax Directive [2022/2523] through
the publication of Legal Notice 32 of 2024. The legal notice was
later complemented by a Guidance Note issued by the Malta Tax and
Customs Authority explaining the purpose of the legal notice, its
interaction with Malta's option to defer the implementation of
parts of the EU Directive, and the compliance obligation of local
entities affected by the EU Directive.
The legal notice applies for fiscal years beginning from 31
December 2023.
By way of background, the EU Minimum Tax Directive, published in
2022, incorporates the OECD's Pillar Two tax rules, also known
as the GloBE Rules, into EU law, which rules ensure that
multinational enterprise (MNE) groups (and large-scale domestic
groups within the EU) with annual revenues of €750 million or
more in two of the last four years, are subjected to a minimum
level of taxation, set at 15%, on the income arising
