Malta offers effective
tax structures for the ownership of the intellectual property and the
channelling of fees generated from licensing rights. The Malta Company
is a very effective international tax-planning vehicle and is suitable
for:
-
licensed investment
services activities;
-
brokerage activities &
commission income;
-
management and consultancy
activities;
-
international trading
business;
-
e-commerce activities;
-
licensed online gaming &
betting activities;
-
ownership & licensing of
patents, copyrights, trademarks, franchises, domain names and other
intangible assets;
-
property ownership &
project management;
-
ownership and leasing of
machinery, foreign registered motor vehicles and trucks;
-
hold assets and investments
of all kinds (intellectual property, real estate, shares & securities, bank
accounts, etc).
Malta IP holding company
receiving Passive royalties
Malta Company structure may either trade in Royalties and generate trading
income or Royalty income received can arise to a Malt could arise may be either
passive income or income arising from actively trading in intellectual property.
“Passive royalties income” defined
The Income Tax Act defines “passive interest and royalties”[1] as interest or
royalties income which is not derived, directly or indirectly, from a trade or
business, and
(1) such interest
has not suffered any foreign tax, or
(2) such interest has suffered
foreign tax, directly, by way of withholding or otherwise, lower than 5%.
Tax refunds on passive royalties income
Shareholders of IP holding companies receiving passive interest income benefit
from a 5/7ths refund of Malta tax suffered by such IP holding company,
effectively a refund of 25% (see tax computations below).
.
