Is Malta issuing a tax residence certificate to the company? I am asking this because many DTA exclude companies which are taxed only for the income produced locally. In this case they tax only remitted income so not sure if it still stays inside the DTA.Hi,
3. There is a particular handling that wr are able to achieve.
If you are truly interested I can PM you to discuss.
In theory this structure should work also with a non-resident UK company having tax residence in Malta according to HMRC guidelines.