ARTICLE · 19 APRIL 2021

Transfer Pricing

KPMG Malta

Explore more from KPMG Malta

The tax environment in Malta has experienced significant changes the past years, in view of the international consensus to combat harmful tax practices.

MaltaTax

Author LinkedIn connections

The tax environment in Malta has experienced significant changes the past years, in view of the international consensus to combat harmful tax practices. Countries around the world are collaborating to improve the coherence of international tax rules and ensure a fair tax environment, through the OECD recommendations.

Developments in Malta

One of the most important initiatives of the OECD is the introduction of Transfer Pricing ("TP") Guidelines, which was proposed through Action 8-10 of the BEPS project. The importance of the Transfer Pricing rules is based on the need to counteract the base erosion and profit shifting, which can result in a distortion of governmental tax revenues. In general, Transfer Pricing refers to methods in determining the arm's length price of intragroup transactions, by considering the pricing, terms and conditions underpinning such transactions.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Related Articles

VAT And Gaming In Malta: Is Your Business Ready For The 1st October Changes?

Malta Introduces New Individual Tax Programme Residency Rules

The Sovereign Group

Public Country-by-Country Reporting

European UnionTax

Grant Thornton Malta

VAT On Gambling In Malta From 1 October 2026

2025 MTCA Annual Report – A Focus On Collection And Compliance And The Impact On Property Transactions

Camilleri Preziosi

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Tax
- Transfer Pricing
- Tax Treaties

Related Comparative Guides

Comparative Guide

Tax

Comparative Guide

Tax Disputes

See more popular content from

Tax

Malta’s New Tax Residence Rules 2026: What Changes In 2027

Malta has consolidated its special tax status schemes into a single framework effective January 2027, offering four distinct categories for foreign residents. Each category provides a flat 15% tax rate on foreign-source income remitted to Malta, with varying minimum annual tax obligations and eligibility requirements based on nationality and income source.

Remittance Basis Of Taxation For Individuals In Malta

Malta's remittance basis of taxation offers favorable treatment for individuals who are resident but not domiciled in Malta, taxing foreign-source income only when received in Malta while exempting foreign capital gains entirely.

Papilio Services Limited

Malta Introduces New Individual Tax Programme Residency Rules

Malta’s new Individual Tax Programme Rules will come into force on 1 January 2027, consolidating four existing residency programmes into a single framework. The rules retain the 15% tax rate on qualifying foreign-source income remitted to Malta but increase minimum tax thresholds, property requirements and application fees.

The Sovereign Group

Malta's New Individual Tax Programme

Malta has introduced a new Individual Tax Programme consolidating its existing residence schemes into a single framework effective January 2027. While maintaining the attractive 15% tax rate on foreign-source income, the programme introduces significantly higher economic thresholds and a five-year renewable status model, signaling a shift toward attracting genuine long-term residents willing to make substantial contributions to the Maltese economy.

Grant Thornton Malta

Malta’s New Individual Tax Programme Rules: Key Changes Ahead Of 2027 Launch

Malta is consolidating its four existing tax programmes into a unified Individual Tax Programme framework, effective January 2027. The new rules introduce significantly higher annual tax thresholds, increased property requirements, and stricter application fees while maintaining the attractive 15% flat tax rate on foreign-sourced income remitted to Malta.

Malta Personal Income Tax 2026: Updated Tax Structure

Malta's personal income tax system is grounded in progressive rates that apply to an individual's chargeable income, that is, total income after deductions, exemptions, and allowances. For the 2026 basis year...

Papilio Services Limited

Taxation

The standard corporate tax rate applicable to companies registered in Malta is 35% and there are no thresholds for reduced rates of taxation applicable.

Malta Introduces Final Income Tax Without Imputation Regulations 2025

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.

Malta’s Individual Tax Programme 2027: Key Changes From 1 January 2027

Malta is consolidating its special tax programmes into a unified Individual Tax Programme effective January 2027, maintaining the attractive 15% flat tax rate on qualifying foreign-source income while substantially raising financial thresholds and property requirements.

Mamo TCV Advocates

Malta Double Tax Treaties

Malta has concluded over 80 double tax treaties with major trading partners worldwide to eliminate double taxation on both passive and active income.

Chetcuti Cauchi Advocates