What It Means for Businesses
Malta's New 15% Final Tax Regime
On 2 September 2025, Malta enacted Legal Notice 188 of 2025, introducing an elective 15% Final Income Tax Without Imputation regime. This new framework allows Maltese companies, certain bodies of persons, and trusts to opt for a flat 15% tax on chargeable income, replacing the traditional full imputation system. The regime includes a five-year lock-in period, exclusion for certain dividend income, and a safeguard rule ensuring tax liability is not lower than under the ordinary system. designed to align with global tax reforms such as OECD's Pillar Two, this move offers businesses strategic flexibility and international tax clarity.
