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UK or Cyprus holding for Malta company

Pembroke

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Mar 10, 2021
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Dear offshorepeople,

We are planning of moving to Malta this summer with family. It's not just for tax reasons. We've lived in many countries and we need a change. It seems to work best for us, I understand Portugal is also often mentioned but in Malta my wife is more likely to find a job in her field. I am planning of liquidating my company here (Belgium) and starting a new one from Malta. I'm active in consultancy, we're talking (hopefully) 75-100K total income in year one with ambition to grow it. There's a bit of a tradeoff between tax savings and additional accounting costs. I understand the setup for a Maltese operating company is to add a foreign holding. I read Cyprus is attractive but also not that cheap (all companies need to be audited) and comes with only a limited number of options for bank accounts. So I also wanted to see if UK would be an option. Commercially I could use a UK holding as 'UK head office' on the website which has a better connotation than Cyprus (which you don't really advertise) which could be beneficial in terms of image for clients (EU corporates). Having spoken to a trust office in Malta, they say UK ltd does not work (anymore?) and that they use Scottish LPs (in combination with 2 maltese entities). They say the 30% refund by Malta to the UK Ltd holding could/would be considered UK income. Something about 'hybrid mismatch rules' which looks like recent legislation. Does this ring any bells? Thanks for any feedback.
 
hey say the 30% refund by Malta to the UK Ltd holding could/would be considered UK income. Something about 'hybrid mismatch rules' which looks like recent legislation. Does this ring any bells?

Have you read the below thread? They would not be saying anything more than what I was saying in that thread.


Malta salaries are quite low depending on your wifes field so factor that into your planning. Also maybe speak to them again about the income threshold before a CFC becomes Malta tax liable.
 
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Thank you for your answer and for the link. So am I right to conclude from that that UK holdings are no longer a good option in a combination with a Malta operating company if the Malta tax refund would exceed 75K?. Regarding your comment on CFC Malta tax liability: i googled it and the threshold is huge (750K trading profit) so that doesn't seem to be an issue.
 
Thank you for your answer and for the link. So am I right to conclude from that that UK holdings are no longer a good option in a combination with a Malta operating company if the Malta tax refund would exceed 75K?. Regarding your comment on CFC Malta tax liability: i googled it and the threshold is huge (750K trading profit) so that doesn't seem to be an issue.
UK holding with Malta local still works for the rebate. I can introduce you to my accountants over there who I register UK companies for as of only a week ago.
They can at least point you in the right direction.

PM me for the details.