Refund system
The standard corporate tax rate is 35%. Following a distribution, eligible shareholders may reclaim part of the tax paid. Eligibility, profit type and timing determine the benefit.
Official source ↗
Jurisdictions
Malta · Ltd
Align trading activity, holdings and distributions, with an operational plan for ongoing administration.
Formation & price
Your GCS formation package.
€2,250
One-time package price · incorporation fees included
Business price excluding any applicable VAT.One private Ltd with one individual shareholder; no additional holding company.
Included in the package
- Formation preparation, document review and a dedicated GCS contact.
- Incorporation including government, local formation, translation and certification fees required for the standard case.
- Tax registration, registered office and company secretary for twelve months; preparation of banking documents.
- Digital incorporation documents and a schedule of ongoing obligations.
From the second year
€1,500 / year —Basic administration, renewing the included address and local statutory roles, plus routine register filings and related registry fees. Excluding applicable VAT; accounting provides any required financial information.
Budgeted separately
Share capital, taxes on your activity, bookkeeping, financial statements, tax returns and audits are outside the formation package. Physical offices, operational substance, nominee directors, special licences and additional entities are quoted separately. Bank-application support does not guarantee acceptance.
The fixed price applies to the standard case described above. Variations and additional services are specified in a written quote before engagement.
Enquire about the Malta packageTax & company structures
Potential advantages for your business.
Company form and special regime
A holding company describes a role within an ownership structure, not automatic tax exemption. An additional holding entity, its administration and any refund applications are quoted separately.
As of September 2026. Benefits depend on activity, actual management, residence and personal circumstances. Company taxation is not the shareholder’s total tax burden.
At a glance
What this company can offer.
- English is an official language
- EU location using the euro
- Can support operations and shareholdings
from EUR 100
Electronic registration fee
Registry fee for authorised capital up to EUR 1,500; included in the GCS formation package. Share capital remains separate.Allow for a registered office, company secretary, accounts and annual return. Tax refunds require separate eligibility checks.
Where it fits
The location must fit the plan.
For businesses able to justify genuine management and activity in Malta. An additional holding company depends on ownership and distribution requirements.
Scope
From context to execution.
- Review of ownership, activity, residence and countries involved.
- Agreed responsibilities, document checklist and open specialist questions.
- Coordination of company or residence documents, banking preparation and local professionals within the agreed scope.
- Document handover and a schedule of ongoing obligations.
The standard rate is 35%. A qualifying 6/7 refund on trading profits can produce a 5% effective Maltese burden, subject to entitlement and procedure. As of 09/2026.
A fiscal unit can consolidate tax calculations for qualifying ownership of at least 95%. It is not an automatic flat-rate election. As of 09/2026.
Eligible entities may elect 15% final taxation under FITWI without refunds, generally with a minimum 5-year commitment. As of 09/2026.
Participation exemption may apply to qualifying holdings. Recipient and income-specific distribution rules still require assessment.
Requirements & Substance
What needs to be clear first.
Actual management and control, banking, decision records and commercial relationships must support the Maltese activity. A trading and holding structure is an option, not a universal requirement.
Timing
A sequence with clear dependencies.
Document review, specialist clearance, filing and account or status decisions follow separate processes. Once the documentation and scope are clear, we agree a schedule. Authority and bank decisions cannot be guaranteed.
Ongoing Duties & Cost Drivers
The structure must work day to day.
Accounting, statements, applicable audit requirements, annual returns and tax accounts create ongoing work. Refund-based structures also require cash-flow planning. There is no universal break-even profit.
German connections
From a German perspective.
German low-tax testing considers refund rights. Passive income and certain services involving German shareholders may fall within CFC rules; the allocation of refunds and substantive economic activity require review.
Management & permanent establishment
Actual central management and fixed business facilities can create German tax exposure; a foreign registered address is not sufficient.
Sections 10 / 12 AO ↗Controlled foreign companies
Control, income type and actual taxation matter. The low-tax threshold is below 15% (as of 09/2026); EU/EEA substance rules require evidence.
Sections 7–13 AStG ↗Foreign-interest reporting
Foreign businesses and shareholdings may trigger notification duties. Conditions, thresholds and deadlines need review.
Section 138(2) AO ↗Exit taxation
Departure or restrictions on German taxing rights can trigger taxation of unrealised gains on covered interests, subject to personal conditions.
Section 6 AStG ↗Remaining German interests
German nationals meeting all relevant conditions may face extended limited taxation for up to 10 years after the departure year (as of 09/2026). Preferential taxation alone is insufficient.
Section 2 AStG ↗Tax treaties
Residence, income, entitlement and the current treaty text determine relief. The existence of a treaty is not a blanket exemption.
Treaty status ↗This overview does not replace case-specific review by directly appointed, qualified legal and tax professionals.
Read on
Guides and terms for this country.
Formation21 September 202619 min
Choosing a legal form abroad: LLC, Ltd, OÜ or Sp. z o.o.?
LLC, Ltd, OÜ or Sp. z o.o.: the eight forms GCS incorporates all have limited liability and differ in statutory roles and tax model. The most flexible is the US LLC: online, no presence required, no US income tax without US business activity. A comparison with table, examples and the recommendation of which form suits which way of life.
Read the articleFormation21 September 202617 min
What forming abroad costs: the package, the fees and the items beside it
A formation price is only a number once it is clear what it includes. This article breaks the cost of a company abroad into government fees, statutory roles, bookkeeping and tax, shows the GCS packages for eight countries, describes the process from first conversation to handover and shows why the US LLC offers location-independent entrepreneurs the best balance of cost and flexibility.
Read the articleFormation21 September 202616 min
After incorporation: annual filings, bookkeeping, registers. The compliance calendar of a company abroad
Incorporation starts the calendar. Every jurisdiction requires at least one register filing, bookkeeping and tax returns each year, many even from a dormant company. This article lists the obligations by country with deadlines and government fees, sets out what GCS takes over from year two and recommends confining the calendar to one country: the one you live in.
Read the article
Terms in the glossary
Questions & Answers
Worth knowing.
Is 5% guaranteed?
No. Income classification and refund entitlement are decisive. As of 09/2026.
Are two entities compulsory?
No. An additional holding needs a clear purpose.
What does a fiscal unit change?
It may consolidate calculations and alter the refund cycle under the applicable rules.
When is FITWI suitable?
When the full comparison, including commitment and shareholder treatment, supports it.
Is there a minimum profitable size?
There is no universal threshold; administration and substance costs depend on the business.