Topic
International & EU tax
Double taxation agreements, EU directives and OECD projects that affect Maltese structures.
131 news items and articles, newest first
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DAC 6 Guidelines published
The Office of the CfR has announced that the Guidelines on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements have been published. The Guidelines have been issued in terms of…
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DAC 6 Reporting deadlines
The Commissioner for Revenue has notified that with respect to cross-border arrangements where the trigger point for reporting took place between 1 July 2020 and 31 December 2020 the deadline for reporting must take…
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Protocol amending the double taxation treaty between Malta and Russia
By means of LN 464 of 2020, the Government of Malta has notified that the Protocol amending the Convention with the Russian Federation for the avoidance of double taxation and the prevention of fiscal evasion with…
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EU Tax Transparency rules to be extended to digital platforms
EU Member States have agreed to extend EU tax transparency rules to digital platforms. Following the proposal made by the Commission in July as part of the Action Plan for Fair and Simple Taxation, the agreed proposal…
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EXPLANATORY NOTES PUBLISHED BY THE EU COMMISSION ON THE NEW VAT E-COMMERCE RULES
On the 30th of September 2020, the European Commission has published explanatory notes on the new VAT e-commerce rules. The notes are intended to provide an explanation of the amendments to the legislation which will be…
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Commissioner for Revenue publishes new guidelines on the ATAD Implementation Regulations
On 31 August 2020, the Commissioner for Revenue published a set of guidelines in relation to the Anti-Tax Avoidance Implementation Regulations. The guidelines on the ATAD Implementation Regulations were issued in line…
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Foreign Direct Investment (FDI) in Malta
FDI contributes to the EU’s growth by enhancing its competitiveness, creating jobs and economies of scale, bringing in capital, technologies, innovation, expertise, and by opening new markets for the EU’s exports. The…
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The EC approves Malta’s COVID wage supplement scheme
On 24th April, the European Commission (EC) has approved Malta’s COVID wage supplement scheme amounting to a total of Eur215 million. This scheme is intended to support enterprises operating in the sectors which have…
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COVID -19 – Concerns related to permanent establishments (PEs) under Tax Treaties
The Organisation for Economic Cooperation and Development (OECD) has recently issued a report addressing the tax implications that COVID-19 will have on cross border employment. Governments across the world (including…
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Tax Treaties – the impact of COVID-19
The Organisation for Economic Cooperation and Development (OECD) has recently issued a report addressing the tax implications that COVID-19 will have on cross border employment. Governments across the world (including…
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Waiver of customs duties and VAT on the importation of medical items into the EU
On 3 April 2020, the EU Commission decided to approve requests from all Member States and the UK to temporarily waive customs duties and VAT on the importation from outside the EU of masks, testing kits, ventilators,…
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Double Taxation Treaty with Belgium
By means of Legal Notice 60 of 2020, the Malta Government has announced that the Double Taxation Relief on Taxes on Income with the Kingdom of Belgium (Amendment) Order, 2013 amending the Double Taxation Relief on Taxes…
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The 6th EU Anti-Money Laundering Directive
Money laundering is a global issue that has the potential to undermine the integrity of any business, as well as the financial sector as a whole. Since many years, the EU has taken part in drawing up international AML…
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The Effect of the 5th AML Directive on Tax Practitioners
January 2020 marked the transposition of the 5th AML Directive (Anti-money Laundering Directive). After the implementation of the 4th AML Directive, the European Union faced new challenges mostly due to the innovative…
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Transposition of the Tax Intermediaries Directive
The Cooperation with Other Jurisdictions on Tax Matters Regulations have been revised by virtue of Legal Notice 342 of 2019 which was published on 17 December 2019. The amendments, transpose the provisions of Council…
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Updated MAP Guidelines
The Commissioner for Revenue has updated its guidance on the use of Mutual Agreement Procedure (‘MAP’). The updated MAP Guidelines provide some additional clarifications to the previous version of the said guidelines.…
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New Double Tax Treaty with Kosovo
By means of Legal Notice 168 of 2019, the Government of Malta has published the new treaty for the avoidance of double taxation with the Republic of Kosovo. With respect to dividends and interest, the two States agreed…
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New Treaty with the Principality of Monaco
The Maltese Government has published the tax treaty with the Principality of Monaco by means of Legal notice 70 of 2019. The tax treaty is modelled on the OECD model tax convention. The treaty provides that the source…
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Controlled Foreign Company (CFC) rule under ATAD 1
By means of Legal Notice 411 of 2018, Malta has like all other EU Member States implemented the EU Anti-Tax Avoidance Directive. The regulations will be applicable as from 1st January 2019 with the exception of those…
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General Anti-abuse rule (GAAR) under ATAD 1
By means of Legal Notice 411 of 2018, Malta has like all other EU Member States implemented the EU Anti-Tax Avoidance Directive. The regulations will be applicable as from 1st January 2019 with the exception of those…
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EU Commission – Moving to Qualified Majority Voting in Taxation Matters?
The EC has invited public feedback concerning a roadmap that proposes decision making on tax matters that could take place by way of qualified majority voting, rather than by unanimous agreement. The Commission’s…
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Interest limitation rules in Malta under ATAD 1
By means of Legal Notice 411 of 2018, Malta has like all other EU Member States implemented the EU Anti-Tax Avoidance Directive. The regulations will be applicable as from 1st January 2019 with the exception of those…
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Malta’s NID rules approved by the EU Code of Conduct Group
Malta’s Notional Interest Deduction (NID) Rules enable undertakings to apply a deduction of notional interest against chargeable income, which notional interest is determined by reference to the undertakings risk…
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Malta deposits its instrument of ratification of MLI with the OECD
On 18 December 2018, Malta deposited its instrument of ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (‘MLI’) with the OECD, together…
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Malta implements the EU Anti-Tax Avoidance Directive (ATAD)
By means of LN 411 of 2018 Malta implements the ATAD which contains four measures in relation to interest limitation, exit taxation, GAAR and controlled foreign company rules. These rules apply to all companies as well…
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OECD’s Multilateral tax treaty instrument enters into force
The OECD’s Multilateral tax treaty instrument (“MLI”) entered into force on 1 July 2018 after the ratification of the said instrument by 5 countries, namely Austria, the Isle of Man, Jersey, Poland and Slovenia. There…
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New Treaty with The Federal Democratic Republic of Ethiopia
By means of LN 182 of 2018, the Government of Malta has published the text of a new double taxation agreement with Ethiopia. In terms of Articles 11 and 12 of the treaty, the two countries have agreed to have a shared…
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European Commission Publishes Proposals for the Taxation of the Digital Economy
The EC has published proposals on the taxation of the digital economy in the Single Market and Recommendation on amending Member states’ Double Tax Treaties with Third Countries. A Digital Services Tax (“DST”) proposes…
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Malta adopts the Multilateral Convention to implement Tax Treaty Related Measures to prevent BEPS
By means of LN 142 of 2018 Malta had adopted in its legislation the Multilateral Convention on implementing Tax Treaty related measures to prevent Base Erosion and Profit Shifting (BEPS). The main purpose of this is to…
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New double taxation agreement with Andorra
By means of LN 118 of 2018, the Government has published a new double taxation agreement with The Principality of Andorra.Of particular interest is that Articles 10, 11 and 12 dealing with dividends, interest and…