MALTA INTERNATIONAL HOLDING COMPANIES
From the 1st of January
2007 it no longer remains possible to incorporate this type of company in
Malta. All International Holding Companies registered until 31st of
December 2006 will however retain their status and tax regime until the
31st December 2010. It is also possible for such International
Holding Companies registered before 31st December 2010, to convert to the
newer and more advantageous tax regime for Malta
Companies.
For information about the new Malta Companies and their very attractive
tax regime, please go to our new Malta
Company pages.
Although it is no longer
possible to register International Holding Companies as explained above,
there might be particular circumstances where it might be advantageous to
acquire an International Holding Company registered prior to 31st December
2006, rather than incorporating a new Malta Company. We have a
number of clients who are owners of International Holding Companies who
would be willing to consider transferring their beneficial ownership in
these companies and therefore please contact
us if you wish to explore this possibility.
The information given
below is therefore only of historical value but is still applicable to
International Holding Companies registered before 31st December 2006 which
will remain valid until 31st December 2010.
International
Holding Companies are not allowed to trade. They are set up as onshore
companies and their aim is to "hold" shares in one or more
overseas companies. A Holding Company may also be set up
to own and manage its own assets held outside Malta.
An
International Holding Company (IHC) is considered to be a normal private
limited liability company under Maltese law. A Holding Company
is allowed to receive royalties, dividends, interest, capital gains, rents, permanent
establishments, branches, holdings and other income arising abroad or
derived from foreign investments, as well as the IHC's own dividends.
The IHC is a normal company and therefore pays corporate
tax at 35% on its world-wide income but non-resident shareholders can then benefit
from considerable tax benefits through a system of tax refunds. ensuring
in many cases that the effective tax rate is zero for non-resident
beneficial shareholders. Click on Taxation
and VAT above to
view detailed information about this.
An IHC
can also have nominee shareholders and directors, thereby ensuring full
anonymity of the beneficial owners of the company. Finally the IHC
is exempt from any transfer duty and exchange control restrictions
applicable under Maltese Law and can therefore freely export its assets;
shareholders also have no restrictions on the exportation of dividends.
Even in
the case of International Holding Companies, shareholders receiving
dividends from the Maltese company can make use of the forty-two double
taxation agreements which Malta has in place. For the full text of all
the Double Taxation Agreements click
here.
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