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Recent content by TarderJoe

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    Malta 5% structure – reduce fixed cost and unshell (ATAD3) proof it

    As an additional benefit you can leverage the profits not taxed until distribution regime and no WHT on interest paid by non-residents, so its a great addition to the structure for treasury purposes. @Don with this you mean that Estonian LP will be used to accumulate the profits and re-invest...
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    Malta 5% structure – reduce fixed cost and unshell (ATAD3) proof it

    Re treaty non-resident UK LTD : I would make the LTD resident in Malta, thus it can form a fiscal union with the Maltese trading LTD and eliminate the need for the maltese holding. In Maltese taxation view the pass through dividends should be viewed to have arisen from UK, because they look...
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    Malta 5% structure – reduce fixed cost and unshell (ATAD3) proof it

    I am holding the securities with an online broker.
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    Malta 5% structure – reduce fixed cost and unshell (ATAD3) proof it

    Ok got your point of waiting out for one year. I hope they will not increase the tax to much or at least only for the large corporations. I am also not doing investments with the Maltese company but for another reason: if you do everything outside Malta, dividend, interests and capital gains...
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    Malta 5% structure – reduce fixed cost and unshell (ATAD3) proof it

    As I am residing in Malta, I can’t own my MT companies directly. When the MT government designed the 5% scheme they needed a way to prevent all the existing businesses (owned by Maltese) to access it. Otherwise they would have eroded their tax base. So they made in a way that it works only for...
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    Malta 5% structure – reduce fixed cost and unshell (ATAD3) proof it

    Hi everyone, The topic has been partly covered here and there already and I am trying to gather the bits and pieces. I am opening the thread because others are facing the same challenge and it will be good to have the situation in Malta and possible solutions up to date. I have a 3-tier...