Maltese Tax for both private and corporate clients

We take pride in our international experience when providing Maltese tax advice.

Over these past years, the European tax landscape has had significant impact on Maltese tax law. Our experience and specialisation in International tax law allows us to better plan Maltese taxes with the foresight of imminent changes and of the general direction of the tax policy within Europe.

We can assist with the review of tax risks and with the alignment with complex compliance and reporting tax policies.

Personal Taxation – Private clients – Malta

One of our areas of specialization is tax planning for expats living in Malta.

Some key areas on which we commonly provide advice are the following:

  • Tax issues connected with pensions
  • Taxation of Maltese-sourced investment income
  • Taxation of foreign-sourced investment income
  • Exit taxation of expats moving to Malta
  • Taxation on departing from Malta
  • Taxation on residents working abroad
  • Taxation on Trusts – Maltese and foreign
  • Inheritance and gift taxes
  • Residency issues
  • Global residence programme and other residence schemes
  • Malta retirement schemes including the united nations pensions programme
  • Returning migrants
  • Salary packaging and fringe benefits
  • Taxation of employee’s share options
  • Taxation of international real estate

Corporate Taxation – Malta

Some key areas we commonly provide advice on from our office in Malta:

  • Impact of Controlled foreign company (CFC) rules
  • Determination of the profits attributable to a permanent establishment – in Malta and abroad
  • Existence – or not – of a permanent establishment in Malta
  • Existence of permanent establishment abroad
  • Interest & Royalties Directive
  • Beneficial ownership under treaties or directives
  • Management and control issues
  • Other aspects of EU tax
  • Parent-Subsidiary Directive issues
  • Taxation on foreign investment income
  • Assistance with Maltese and foreign withholding taxes
  • Residency under tax treaties
  • Structuring investments abroad
  • Relief for tax paid abroad
  • Fixed rate foreign tax credit matters
  • Tax treaty application
  • Tax treaty interpretation
  • Taxation of foreign real estate owned by Maltese taxpayers
  • Taxation on transfers of corporate seat (re-domiciliation) to and from Malta
  • Withholding tax refunds

VAT services

We assist with all aspects of VAT compliance, from registration to setting up routine meetings with the clients to ensure filing of returns within set deadlines and the preparation and filing of VAT returns.

The following are some areas on which we commonly provide advice on VAT matters:

  • VAT issues on intra-community supplies and acquisitions
  • Disputes with the tax authorities
  • Eligibility for registration
  • Liability to VAT in Malta
  • VAT on services
  • VAT in e-commerce
  • VAT grouping
  • VAT issues generally
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    Professionals in Maltese Tax & VAT Advisory

    Partner

    Ivan Zammit
    Tax Director

    Brian Borg

    Partner

    Ivan Zammit

    Ivan joined Sheltons in 2006 in Denmark and soon after became director in charge of our Copenhagen office. Ivan is nowadays the partner in charge of our Malta office as well as a director of Sheltons Italy.

    After receiving his Adv. LLM in international tax law, Ivan accepted a position as a teaching assistant at the International Tax Centre (ITC Leiden) at Leiden University, The Netherlands, where he was involved in the ‘Fundamentals of International taxation’ and ‘Tax treaties’ courses. He continues to lecture on a regular basis on courses organised by ITC Leiden, with particular focus on Transfer Pricing. He also lectures yearly on various areas of international tax law.

    Ivan advises private clients as well as multinational groups on a wide range of tax related areas typically involving cross-border activities. His specialisation includes:

    • Personal tax planning (especially upon relocation within the EU)
    • Transfer pricing
    • APAs, Tax rulings and opinions
    • Tax accounting for complex transactions
    • Best practice review for corporate income taxes

    Ivan speaks English and Maltese and is fluent in Danish and Italian. He also reads Spanish and French.

    Publications

    Malta National Reporter for IFA Congress in Lisbon 2025, co-authoring the Maltese chapter on: “Subject 2: Improper use of tax treaties and source taxation — policy, practice and beyond.”

    Co-author of book published by Thomson Reuters, entitled ‘Transfer Pricing in Ibero  America, USA, and UK’, with his chapter on UK transfer pricing.

    Country author of the ‘Bloomberg country tax guide for Malta’ – Bloomberg Tax online platform, updated regularly. Note: This publication is available to subscribers of ‘Bloomberg Tax’ and, in 2020, was honoured with the prestigious award of ‘International Tax Contributing Author of the Year’ by Bloomberg Tax.

    Peer-reviewed paper on ‘Centralized Intellectual Property Business Models – Tax Implications of EU Patent Box Regimes’. IBFD, Bulletin for International Taxation, 2015 (Volume 69), No. 9.

    Amongst other publications.



    E-mail:[email protected]

    Tax Director

    Brian Borg

    Brian joined Sheltons in 2017 and is currently the Director of Operations at the Sheltons office in Malta where he oversees internal processes, team development, and operational efficiency.

    In 2021, Brian obtained his Master’s in Accountancy through ACCA, becoming an Associate Chartered Certified Accountant and a Certified Public Accountant registered with the Accountancy Board in Malta. His passion for taxation led him to also pursue an Advanced Master’s in International Taxation at the renowned University of Amsterdam, which he completed successfully in 2024. His thesis examined the tax regimes available to high‑net‑worth individuals across Europe, with particular attention to the social considerations influencing applicants’ decisions.

    Brian advises both Maltese and international clients operating in Malta, assisting with a broad range of tax, corporate, finance, and accounting matters.

    Outside of work, Brian enjoys unwinding with a Ken Follett or Stephen King novel, or free‑diving along the Maltese coastline.

    He speaks English and Maltese and is fluent in Italian.



    E-mail:[email protected]

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