CRS - AEOI - FACTA exchange informations to Malta

[kkein]

according to Tax Information Exchange Agreements (TIEAs) - OECD , i see no appearence of Malta anywhere. Does Gibraltar and Malta really have a TIEA in place?

 

[Sols]

according to Tax Information Exchange Agreements (TIEAs) - OECD , i see no appearence of Malta anywhere. Does Gibraltar and Malta really have a TIEA in place?

Take a look at this: CRS by jurisdiction - Organisation for Economic Co-operation and Development

Both Malta and Gibraltar participate in CRS/AEOI.

 

[kkein]

Take a look at this: CRS by jurisdiction - Organisation for Economic Co-operation and Development

Both Malta and Gibraltar participate in CRS/AEOI.

Is that the same thing?
From my understanding:
CRS: your bank will report your movements and saldo to the tax authority where you are tax resident (Malta, or Gibraltar).
TIEA: Country A can ask Country B about financial information in B for citizens who are tax resident in A. Example: a Swedish national opening a Company and a related bank account in the Seychelles.

 

[Malta]

Hi everyone, I'm new on the forum, but I can tell you my story, I'm not Maltese, I opened my first company in 2003 in Malta, and many things have changed since then.
Before they made you do what you wanted, now you have to declare and in any case do what you want, becausi is Malta, Mela! ( mela is an maltese esclamation).
Basically, if you don't want to pay 35% of taxes, you must have a holding company to take advantage of the PEX schemes and therefore reduce the taxes by 95%.
You can of course charge yourself with costs from offshore companies, but the tax department may dispute this practice, usually they don't, but with all the new rules, things can easily get out of hand.
Being in Malta is useful above all as a base for international interfacing, a company in Malta, Holding in the UK or HK, and you are happy with taxes, or at least, for me it is like that, then in Malta there are more consultants than sand on the beaches, therefore each one has his idea, however, both for the operating methods and for the opportunities, I always recommend Malta

 

[BlueMist]

I never came across Malta trading company with UK holding. Usually It is Malta co + Malta holding or Malta co + Cyprus holding. And sometimes this Cyprus holding is also owned by Seychelles holding

 

[Malta]

I never came across Malta trading company with UK holding. Usually It is Malta co + Malta holding or Malta co + Cyprus holding. And sometimes this Cyprus holding is also owned by Seychelles holding

yes for sure, there are many eligible configurations for work, but for Cyprus there are many considerations to make, both on Hong Kong and Saychelles, in MFSA if you track the BO well you have no problems.
But surely the Malta system has always been connected to UK, UK has always been with HK, then from HK to SY or BVI it is a natural path.
But this is only my vision\opinion, if I do this, I have no problem opening bank accounts or preparing tax returns.

Regarding the Holding in Malta with Trading in Malta , the territoriality issue arises, if you are a resident of Malta you pay 35% of taxes, if the trading moves the profit to the Holding in Malta you have the local PEX, example 1: 100k profit, transfer of dividends to Holding UK, or HK can invoice the UK for costs, or receive dividends and the company may apply the offshore tax claim, then 0% local tax, 0% UK and HK Tax. example 2: 100k profit, 35% local tax 35k, detax with PAX -95%, total tax to pay in Malta € 1,750 each 100k profit.
Then there are the management costs, Malta is expensive in management compared to UK or HK.

 

[lonizzita]

Hi everyone, I'm new on the forum, but I can tell you my story, I'm not Maltese, I opened my first company in 2003 in Malta, and many things have changed since then.
Before they made you do what you wanted, now you have to declare and in any case do what you want, becausi is Malta, Mela! ( mela is an maltese esclamation).
Basically, if you don't want to pay 35% of taxes, you must have a holding company to take advantage of the PEX schemes and therefore reduce the taxes by 95%.
You can of course charge yourself with costs from offshore companies, but the tax department may dispute this practice, usually they don't, but with all the new rules, things can easily get out of hand.
Being in Malta is useful above all as a base for international interfacing, a company in Malta, Holding in the UK or HK, and you are happy with taxes, or at least, for me it is like that, then in Malta there are more consultants than sand on the beaches, therefore each one has his idea, however, both for the operating methods and for the opportunities, I always recommend Malta

Hello
with the structure you made
Malta + uk, have you had problems opening bank accounts for the Maltese company?

Also they told me that from this year you pay directly 5% no more 35% with a 30% this is correct?

also UK, must it have its headquarters in the UK, or being a holding company can you have its headquarters in Malta? with operational headquarters I say: local director and office

 

[Malta]

Hello
with the structure you made
Malta + uk, have you had problems opening bank accounts for the Maltese company?

Also they told me that from this year you pay directly 5% no more 35% with a 30% this is correct?

also UK, must it have its headquarters in the UK, or being a holding company can you have its headquarters in Malta? with operational headquarters I say: local director and office

HI!
As long as we talk about Malta and the UK and not about Italy, and therefore the tax systems are not aggressive but diligent and punctual, the problem to open the accounts is no longer the manager, the introducer or the fate, but based on the KYC and DD procedure, so it always depends on how you do things, if you open a $ 800 BVI you will never do anything, but if a HK company owned by a UK Holding with a branch in Malta, has an office in Malta, if HK documents have apostille and in London or Malta there is an office, there are no problems.
In Malta there is always a lot of rigidity to open accounts for non-resident companies, but if you have a company in Malta, you will have an account in Malta for business costs and everything else will be outside of Malta, this is a good rule especially for Maltese companies.

The payment of taxes always takes place in the same way, there are simplified or pre-set methods, which the accountant can apply from time to time or must follow depending on whether you are following very specific schemes (e.g. PEX, Reimbursement, Costs, etc.), for resident companies is always 35% of what you declare and for non-residents 5%.

I noticed that if I have the Holding in HK the basnche create problems for me (which you obviously solve with costs, documents, apostille etc ..), if the Holding is in the UK I don't find any problems, if the Holding is in Malta I don't find any problems, Malta is obviously the most expensive solution compared to the three.
If you have no interest in HK or Saychelles \ BVI, you can opt to have everything in Malta (Trading company and Holding Company) the highest cost you will have compared to having Offshore companies, they allow you to have an easier management.

Normally you have to pay 35% to maintain the level of taxation in the European market, in some cases you can request to pay only 5%, but it is a procedure that you have to agree on, but we must always remember that many states still ask to pay taxes in the territory of citizenship, if where the citizen has moved with his / her fiscal residence, in territory with reduced or much lower taxation than the territory of citizenship, so, it all depends on your tax profile.

 

[ghouldog]

I’ve read the malta CFC rules and i found this:

The CFC rule shall not apply in relation to an entity or permanent establishment:

1. with accounting profits of no more than seven hundred and fifty thousand euro (€750,000), and non-trading income of no more than seventy-five thousand euro (€75,000);

It means that foreign company controlled by director resident in Malta with porfits less than 750k is not taxable in Malta?

@Martin Everson @Osleak
I think the key word is "AND" (i.e. you need to fulfil both thresholds). Basically, you can have a holding company with as much non-trading income (i.e. dividends) as you want as long as you do not have any trading income (which a holding company would not), and you will be fine from a CFC perspective. Would you not agree?

 

[jackfrost]

Hello
with the structure you made
Malta + uk, have you had problems opening bank accounts for the Maltese company?

Also they told me that from this year you pay directly 5% no more 35% with a 30% this is correct?

also UK, must it have its headquarters in the UK, or being a holding company can you have its headquarters in Malta? with operational headquarters I say: local director and office

The 5% direct rule is not for the classic maltese active ltd + outside holding ltd i have been told.

 

[jackfrost]

Frankly the system in Malta is so good, dont f**k with it. Do the classic Maltese LTD + external holding. Move / live on Malta, pay the 5k "expat" tax no questions asked and period. It does not get easier, cheaper, stress-free and legal in the EU. Sleeping well is a very underrated commodity.