The Minister of Finance has in his Budget Speech for the year 2024 announced that Malta will apply the derogation provided for in the EU Minimum Tax Directive and therefore will delay the introduction of the 15% minimum tax rate for companies forming part of a group with an annual turnover of at least €750 million.
This means that the application of the Income Inclusion Rule (‘IIR’) and the Undertaxed Profits Rule (‘UTPR’) will be deferred by up to six years. Furthermore, at this stage, a Qualified Domestic Minimum Top-up Tax (‘QDMTT’) is not expected to be introduced. This position will be assessed in future years in the context of global international tax developments. Furthermore, no changes will be made to the full imputation system and new forms of grants and tax credits, also referred to as Qualified Refundable Tax Credits (‘QRTCs’), are expected to be introduced.