Malta published formal transfer pricing rules, aligning with current global standards, adopting the arm's length principle as from 1 January 2024.

Intragroup financing arrangements are a common feature in multinational groups. Loans, guarantees, and cash pooling structures offer flexibility and centralised control over liquidity.

On 19th January 2024 the Commissioner for Tax and Customs ('CfTC') issued interpretative guidelines in terms of Article 96(2) of the Income Tax Act which are to be read in conjunction...

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

It has become generally accepted that the international tax system is based on the principle that the profits of a business should be taxed in the countries in which it created value.

The Cooperation with Other Jurisdictions on Tax Matters (Amendment) Regulations, 2019 have recently been amended by virtue of Legal Notice 342 of 2019 in order to transpose Council Directive

At the core of every transfer pricing policy is the requirement to demonstrate that related-party transactions are consistent with market terms. Benchmarking is the process of identifying and applying comparable data to support this principle.

With tax authorities increasing their focus on transparency, Country-by-Country Reporting (CbCR) has become a key requirement for multinational enterprises (MNEs).

Transfer pricing compliance has become an essential aspect of multinational enterprises (MNEs) adhering to global tax regulations.

On 24th September 2019 Starbucks won their appeal against the European Commission's decision of 2015, over a €30 million tax fine issued by the Commission. The General Court of the European Court ...

Malta's transfer pricing framework has evolved significantly with the introduction of formal Transfer Pricing Rules in 2022 and subsequent amendments. As the transitional period approaches its end in 2027, international businesses with related-party cross-border transactions must understand how these regulations affect their operations and what documentation requirements they need to meet to ensure compliance with OECD principles and arm's length pricing standards.

On 17th December 2019, regulations to transpose Directive 2018/822 on mandatory disclosure rules were published in Malta enacting new mandatory exchange of information obligations on intermediaries and taxpayers.

Act XVIII contains fiscal amendments to implement some of the Budget Measures for 2021. We highlight the salient income tax and duty measures enacted.

When the International Monetary Fund first raised the concept of a service aimed at large taxpayers, the officials at the Malta Tax and Customs Administration (MTCA) were taken aback.

A local file is meant to provide detailed information with respect to transactions entered into between the entity and its related entities within the MNE group.

As businesses expand across borders and establish related-party arrangements, transfer pricing becomes increasingly relevant.

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

The OECD's Base Erosion and Profit Shifting (BEPS) initiatives have significantly influenced international tax policies, focusing on curbing tax avoidance...

On 10 September 2024, the Grand Chamber of the Court of Justice of the European Union delivered a landmark judgment in favour of the European Commission in the appeal case C-465/20...

This article examines the specifics of LVAS in the context of transfer pricing regulations.