Tax Update in relation to Malta Legal Notice 32 of 2024

28th February 2024 • News

We would like to bring to your attention the below tax update concerning Malta’s Legal Notice 32 of 2024 transposing into Malta income tax law, the European Union Directive on Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups Regulations 2024. Malta has elected, in terms of Article 50 of the Directive, for a delayed application of the ‘Income Inclusion Rule’ (IIR) and ‘Undertaxed Profit Rule’ (UTPR):

Malta Transposes EU GloBE Directive Into National Law

Malta has transposed the provisions of Minimum Taxation Directive (2022/2523) of 14 December 2022 into national law, laying down rules on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the European Union by virtue of Legal Notice 32 of 2024, “European Union Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups Regulations, 2024”.

Although the regulations will be deemed to have come into force on 31 December 2023, as a result of the election taken in terms of Article 50(1) of the said EU Directive, the application of the regulations will be limited to the measures that are of relevance to ensure the proper functioning of the system of global minimum level of taxation for multinational enterprises and large-scale domestic groups.

The legal notice primarily transposes the relevant definitions and administrative provisions in relation to the EU Directive. The full version of the legal notice can be found here.

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