Europe EU
Founders running a two tier trading and holding structure, Malta
Malta's Refundable Imputation system lets non resident shareholders claim a 6/7 refund on the 35% CIT, taking the effective rate to 5%. Requires a holding plus trading structure and onshore substance to satisfy MFSA and ATAD.
Refundable Imputation5% effectiveMFSA
Start setup {placement} 4 min · no card required
Corp tax
35%
Fastest setup
2 weeks
Tax treaties
70
Region
Europe
What you'll need
- No resident director required
- Local registered office required
- Economic-substance test applies
- Minimum capital: EUR 1,165
- Administrative language: English
- Legal system: Civil law
Tax and treaty profile
- Corporate tax 35%
- Effective rate ~5%
- Tax treaties 70
- VAT rate 18%
- Withholding on dividends 0%
Key treaty partners
UKGermanyItalyUAESingaporeChina
Banking and payments
- Banking takes 2 to 4 weeks with KYC
- Stripe supported
- Wise supported
- Crypto banking available
- EMI license framework available
Considerations
If any beneficial owner is a US person
The 6/7 refund creates PFIC and GILTI exposure for US shareholders, and the system is under continuous EU scrutiny. If your cap table includes US persons:
6/7 refundPFIC + GILTIEU scrutiny