Global Minimum Tax Directive Transposed into Maltese Law

The European Union Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups Regulations, 2024, transposing Directive 2022/2523, were published by LN 32 of 2024.

With the Budget for 2024 it was announced that Malta will opt, for 2024, for the derogation granted in terms of Article 50 of  Directive 2022/2523, which allows Member States in which no more than twelve ultimate parent entities of groups within the scope of the Directive are located, not to apply the Income Inclusion Rule and the Undertaxed Profit Rule for six consecutive fiscal years beginning from 31 December 2023.  The new Regulations are limited to the relevant provisions of the Directive which have been established as the minimum measures which are of relevance to ensure the proper functioning of the system of global minimum level of taxation for multinational enterprise groups and large-scale domestic groups.