Maltese non-dom resident + fiscal unit

[Cari]

Hi! In one of the threads I found a statement, that if a shareholder of the Maltese fiscal unit lives in Malta and is a non-dom, the effective tax rate is still 5% and the dividends from such fiscal units are not taxed.
Is that correct? Aren't these dividends are considered Maltese-sourced income that would have to be subject to taxes in Malta?

 

[PhantomOf ThePits]

Hi! In one of the threads I found a statement, that if a shareholder of the Maltese fiscal unit lives in Malta and is a non-dom, the effective tax rate is still 5% and the dividends from such fiscal units are not taxed.
Is that correct? Aren't these dividends are considered Maltese-sourced income that would have to be subject to taxes in Malta?

Fiscal unit between a Maltese TradeCo and for example Cyprus HoldCo leads to effective 5% group taxation (without the need to wait for the 30% refund).
However you'd need to do also a group audit in addition between the Maltese TradeCo/ CY HoldCo.

The money could be sent from Malta TradeCo as Divs to the CY HoldCo.
If you then do NOT remit the dividends from CY to yourself to Malta, as a Maltese NonDom you'd not be taxed on that div payment from the CY HoldCo.