Onshore Status of Maltese International Companies

Prior to 1996, Maltese law admitted two basic forms of corporate structure which were available to non-residents who wished to register a Maltese company for commercial or asset trading purposes. These were [i] the onshore company with an issued share capital of Lm10,000 (USD25,000) and [ii] the low-tax (5%) offshore trading or zero-tax non-trading company.

In 1996, the offshore regime was transformed into a new onshore regime. Malta adopted a new Companies Act and amended the Income Tax Act to create the International Holding Company (IHC) and the International Trading Company (ITC) of today. These are normal Maltese onshore companies taxed on a worldwide basis at the normal corporate tax rate (35%) and are therefore not perceived to be tax avoidance structures. Significant tax savings can be achieved by refunds received by non-resident shareholders bringing the overall tax liability down to 4.17% and in some cases to 0%.

Sociétés de Commerce International