Malta does not have a specific holding company structure, however, the domestic tax treatment in relation to the different types of income makes a holding company in Malta a very attractive option. The participation exemption together with the tax refund system make it ideal to hold shares, securities and business assets in a holding company. Also, personal assets including yachts, residential property, aircrafts and art can benefit from tax on forming holding companies in Malta.
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Where the company does not opt for participation exemption, or in case it does not apply, holding companies are subject to 35% tax on income less deductible expenses. After dividends are distributed, shareholders are entitled to claim tax refunds of all or part of the tax incurred on the company level. The following tax refunds are available for companies in Malta:
Whether shareholders are resident or non-resident in Malta, no tax I generally withheld on dividends distributed by a Maltese registered company to its shareholders.
Furthermore, disposal of shares in a Maltese company by non-residents are generally exempt from tax in Malta.
Pure holding companies fall outside the scope of VAT in Malta, except in the case of Intra-Community Acquisitions of services, which are subject to the reverse charge rules.
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