The MAP Guidelines published on the website of the Office of the Commissioner for Revenue have been revised. Specifically, the text under the heading: “Suspension of Collection of Tax During a MAP” has been replaced to reflect the amendment to article 41 of the Income...
The Tax Accounts (Income Tax) Rules have been amended through LN 194 of 2019, published on 6 August 2019. As a result of the amendment: Profits derived through the application of the participation exemption in terms of Article 12(1)(u) of the Income Tax Act (ITA) are...
The convention signed between Malta and Kosovo for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income was published by virtue of LN 168 of 2019. The Convention will enter into force with effect from such date as...
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,...
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...
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...
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...
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...
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....
