Notional Interest Deduction Guidelines updated

On 11 July 2019, the Office of the CfR published updated guidelines on the Notional Interest Deduction rule. The updated guidelines include a new paragraph ‘xi’ which is applicable from YA2020: “(xi) Accounting Periods other than 12 Months To further approximate the neutrality between debt and equity financing,...

EU Tax Dispute Resolution Mechanisms Regulations 2019

The European Union Tax Dispute Resolution Mechanisms Regulations, 2019 came into effect on 1 July 2019 (LN 159 of 2019 published on 12 July 2019). The rules, which implement the provisions of Council Directive (EU) 2017/1852, regulate the  mechanism for resolving disputes between Malta and other...

MIT Master Class delivered by OECD Head of ATP

On 14 June 2019, the MIT had the honour of hosting Mr. John Petersen, Head of Aggressive Tax Planning – OECD, who delivered the MIT Master Class on Transposing ATAD II Anti-hybrid Rules. Mr. Petersen is responsible for Working Party 11 which produced the BEPS Reports...

Mutual Agreement Procedure – CFR guidelines

The Office of the Commissioner for Revenue has issued guidelines on the Mutual Agreement Procedure (MAP) which may be invoked with a view to resolving an international tax dispute, pursuant to the MAP provision in a Double Taxation Agreement or the EU Arbitration Convention (90/463/EEC). The...

Consolidated Group (Income Tax) Rules, 2019

The Consolidated Group (Income Tax) Rules, 2019 (LN 110 of 2019), were published on 31 May 2019. The rules, which enable a parent company and a 95% subsidiary to form a fiscal unit, come into force with effect from YA 2020 in relation to fiscal units...

Malta – Monaco Double Tax Treaty

In virtue of L.N. 91 of 2019, the Double Tax Treaty between Malta and the Principality of Monaco, as published as a Schedule to Legal Notice 70 of 2019 entered into force on 16 May 2019....

MIT Master Class Series

The Malta Institute of Taxation launched its Master Class Series on 25thJuly 2018, with the first session entitled Digitalisation: Is it a Catalyst for International Tax Reform? The MIT Master Class is an interactive discussion forum on select tax topics, led by a local or foreign...

The Basis of Taxation for Individuals

The Direct Tax Committee of the Malta Institute of Taxation has prepared a Technical Paper on the basis of taxation for individuals...

Technical Paper on the basis of taxation for individuals

The Direct Tax Committee of the Malta Institute of Taxation has prepared a Technical Paper on the basis of taxation for individuals, examining the motion of 'residence' of individuals for tax purposes and with a particular focus on employment income. A copy of the Technical...