Holding structures between Germany and Malta: Leveraging growth opportunities while avoiding tax risks

When companies think in European terms, structural questions inevitably arise sooner or later: How can shareholdings be organised in a way that facilitates market access, attracts international investors and reduces the tax burden – without compromising legal certainty?

A frequently chosen option is the establishment of ...

Over the past years, many international entrepreneurs have incorporated companies in Malta – often for tax or structural purposes. However, not all companies did remain active in the longer term.
Until recently, business owners who wanted to close their Maltese entity had only two options: a formal liquidation or a strike-off initiated by the Malta Business Registry ...

The Malta Permanent Residence Programme (MPRP) is open to all third-country, non-EEA and non-Swiss nationals who have a stable income and sufficient financial resources.

The Maltese Government had announced changes to its Malta Permanent Residence Program (MPRP) through Legal Notice 146 of 2025, published on July 22, 2025. These changes affected all applications submitted on or ...

Malta – 15% Flat Tax for Highly Qualified Individuals

Malta offers an attractive tax package for highly qualified professionals in specific licenced sectors. Under the Highly Qualified Persons Rules (S.L. 123.126), eligible individuals benefit from a flat income tax rate of 15% on qualifying employment income.

This scheme is designed to attract and retain skilled professionals in key sectors ...

Up until recently, the Scottish Limited Partnership (SLP) presented an option for individuals interested in forming a corporate structure being a legal entity of its own and allowing the ultimate owners a level of confidentiality at the same time.

An SLP must have at least one general partner, who is responsible for management, debts and other obligations and at least one ...

The new Initiative is intended to award citizenship as recognition for exceptional achievements - no longer as a commodity that can be purchased. Foreign individuals, European and third country nationals, who have demonstrated an extraordinary service to the country or to humanity or whose naturalization is of exceptional interest to Malta may be granted. These may include scientists, artists, athletes ...

The EU Entry/Exist System (EES), operational since 12 October 2025, is an automated border control system for non-EU nationals entering or leaving the Schengen Area for short stays (up to 90 days in any 180-day period).

It applies to all external Schengen borders, including air, land and sea crossings, and replaces traditional passport stamps with electronic registration of entries and exits. ...

Malta offers sunshine, quality of life and attractive tax conditions – no wonder that more and more entrepreneurs and other active individuals are taking the plunge and moving there.

But be careful: if you move without preparation, you quickly risk high tax burdens, legal problems and unnecessary trouble with the authorities at home and abroad.

Why professional planning is crucial

Moving to Malta ...

Malta has opened up a new, alternative tax route that offers opportunities for start-ups and smaller structures with annual profits of up to approximately EUR 100,000. Companies can choose to pay a final tax rate of 15% on their profits.

With the introduction of the 'Final Income Tax Without Imputation Regulations, 2025', Malta now offers this option, which companies must commit ...

The UK previously had a very business-friendly tax system. From 6 April 2025, the UK's non-dom tax system was abolished. The reform of this tax system means that the tax benefits associated with non-dom status will also be abolished. Many entrepreneurs who have utilised this non-dom status are taking flight to protect themselves from taxation of their foreign income in ...

The below article summarizes the rationale and the current minimum share capital requirements for gaming licenses in Malta.
The Capital Requirements Policy, which is a binding instrument in terms of Article 7 (2)(a) of the Gaming Act, serves as a foundation for ensuring the financial soundness of legal entities licensed by the Malta Gaming Authority (the “MGA”/ “Authority”), holding a licence ...

Kresse Law is pleased to announce that our client, The Millionaires’ Club Ltd (TMC), has been granted a type 3 gaming licence, number MGA/B2C/912/2021, effective from 5 March 2025. With TMC, you can win a variety of luxury prizes, including luxury watches, high end electronic devices, trips abroad, accumulating in a jackpot prize of up to one million Euros. TMC ...

In recent years, Malta has emerged as a burgeoning hub for electronic sports, better known as “eSports”. Esports is where professional players compete with each other in organised, competitive videogame sports tournaments.

With its strategic location, robust digital infrastructure, and proactive regulatory initiatives, Malta is creating an environment where eSports can thrive, both locally and internationally.

Strategic Vision

Malta’s rise as an eSports ...

Malta continues to solidify its reputation as an attractive destination for third country nationals with its robust residency and business incentives. The Malta Permanent Residence Programme (MPRP) is a key pillar of this appeal, offering third country nationals and their dependants a pathway to permanent residency with numerous benefits. Prospective applicants are encouraged to take full advantage of the current ...

Malta has a progressive approach to cryptocurrency taxation, benefiting from a favourable regulatory framework. 

Under the Maltese crypto taxation regime, a distinction is made on whether an individual is investing in cryptocurrencies as a private individual or through a Maltese company.

Taxation of Cryptocurrency for Individuals

In Malta, the tax treatment of cryptocurrencies for individuals depends on the nature of the activity and ...

The 2024 edition of SIGMA Europe in Malta, having started yesterday, 11 November, is going to be the meeting point of around 27,000 delegates, over 200 exhibitors and some 550 speakers at the Mediterranean Maritime Hub (MMH). These numbers highlight the increasing importance of the event for the iGaming industry.
SIGMA, being the leading iGaming congress and exhibition, has further announced ...

Malta is a vibrant hub and offers a favourable environment for financial services providers.

Other than “physical” banks, offering a range of services, including accepting deposits, providing loans, and offering current, savings or other interest-bearing accounts as well as investment products among others, Electronic Money Institutions (EMIs) can be used for online transactions and purchases; they primarily focus on electronic transactions, ...

Clients of Dr Kresse International Law Firm and Kresse Corporate LTD for whom we set up companies in Malta, regularly need a banking relationship on the island to process their payment transactions.

Therefore, we are very often asked to support in the process of bank account opening and choosing the right finance partner for our client companies.

Clients who incorporate a company, ...

Re-domiciliation is a way in which an entrepreneur can move his existing company from one jurisdiction to another, in this case Malta.

As a licensed company service provider in Malta, we frequently guide and assist clients in registering their companies with the Malta Business Registry – either as a re-domiciling process or as a new company incorporation.

The process of Re-Domiciliation

Re-Domiciliation can ...

Google has announced significant changes to its gambling advertising policy in the German market. Taking effect from 25 September 2024, the update introduces stricter requirements for gaming operators and brokers (gaming affiliates) seeking to advertise on Google’s platforms in Germany.

Specifically, only operators and intermediaries licensed by Germany's gambling regulator GGL (Gemeinsame Glücksspielbehörde der Länder) will be eligible to apply for ...

Since Malta became a member of the European Union on 1st May 2004 the population of the Maltese Islands has increased from around 402,000 to almost 550,000 at the end of 2023.

Is Malta a paradise – no, certainly not. So why are the islands still attracting many people to live and work here?

I relocated to the rock in the Med ...

Malta, a small yet dyanmic Mediterranean island, is rapidly emerging as a hub for innovation and entreprenuership. The Malta Enterprise is the Government's economic development agency which nurtures the country's start-up ecosystem. Through a range of funding programmes and support initiatives, Malta Enterprise helps turn innovative ideas into thriving businesses. Two great funding opportunities offered by the Malta Enterprise are ...

Valuable insights on the future of international gaming rules were discussed during the CasinoBeats Summit 2024, a premier event which took place in St. Julian's, Malta between Tuesday 21st and Thursday 23rd May, 2024. The event brought together regulators and professionals in the industry to discuss the everchanging landscape of global gaming. Prominent individuals who contributed to the conference included ...

The new Malta Small Commercial Yacht Code (SCYC), effective from 1st April 2024, renders the Maltese Flag even more attractive, filling a regulatory gap in the market. The SCYC caters for the specific needs of Small Commercial Yachts, meaning yachts from 12 meters to 24 meters in length, engaged in commercial operations, with a passenger limit of 12.

The Code is ...

Starting from January 1st 2024, the value added tax for those clients, wanting to rent a small ship under 24 meters in length, used solely for the navigation within the territorial waters of Malta, was reduced to a Malta VAT rate of 12% for short-term boat hires (Legal Notice 231 of 2023).

What do you need to consider?

For short-term hiring (up ...

The gross domestic product (GDP) growth of the EU’s southernmost country is projected to reach to 4.0% in 2023, and to ease slightly to 3.8%, and 3.7%, in 2024 and 2025, respectively.

Still, these figures show that Malta’s economic growth is forecast to remain robust with an inflation rate projected to moderate to 3.3% in 2024 and 3.1% in 2025.

Malta's economy ...

Making Malta the jurisdiction of choice for the niche superyacht industry by fostering a sustainable ecosystem supported by reliable infrastructure, quality services and a skilled workforce – this is the key factor of the Malta Government’s new strategic vision for the further development of the maritime sector on the Maltese Islands.

Over the last 16 years, the number of superyachts exceeding ...

Over 800 exhibitors and sponsors, around 25,000 delegates and 250 speakers – these are the record figures of this year’s SIGMA EUROPE, taking place in Malta from 13 – 17 November 2023. The current year features a record demand for the leading iGaming show, gathering the world’s gaming community on the 'Roc in the Mediterranean'.

The team of Kresse Law will ...

In Malta, one gaming license can cover a number of companies (minimum 2 operational entities and one holding company as the parent), each of them then being authorised to operate as an MGA licensee.

The Malta Gaming Authority (MGA) predominantly offers two types of licences, either a business-to-customer (B2C) license to provide gaming services, or a business-to-business (B2B) license to provide ...

These three words spoken by CEO Ivan Filletti of Gaming Malta perfectly capture the positive sentiment behind this year’s Casino Beats Summit at the Intercontinental Conference Centre in St. Julian’s, Malta (23 – 25 May 2023).

Kresse Law attended the two-day conference, which gathered over 2,000 I-Gaming leaders and industry experts, with an agenda focused on Global Casino, leadership and affiliation.

On ...

As a member of the Finance Malta delegation Dr Kresse International Law Firm and its consulting arm KME Consulting Group will participate in the conference for family offices, high net worth wealth managers and private banks from the DACH region.

The PRIVATE DACH WEALTH FORM is going to take place in Vienna on 9th May 2023 at the prestigious location of ...

Leading German commercial law firm: Over 10 years of Malta expertise and high client confidence

For over 10 years, since February 2013 to be exact, the German law firm DR KRESSE INTERNATIONAL LAW FIRM has been advising primarily German-speaking clients on their business in and via Malta as an international hub.

The firm's founder and owner, Dr Hermann Kresse, former in-house counsel ...

The framework conditions for foreign investment in Malta have been strengthened further by a recent initiative of Malta’s financial watchdog.

MFSA, the Malta Financial Services Authority, launched a new Corporate Governance Code for authorised entities on Friday, 5th August 2022.

The Code provides a list of guiding principles, designed to enhance the legal, institutional, and regulatory framework for good governance in the ...

The FATF is a global anti-money laundering institution. It monitors the integrity of the international financial system across countries. Thus, as the responsible organisation, it has put an end to the discussions surrounding the 'GREY LISTING' of Malta, the well-known financial centre of the Mediterranean.

The Prime Minister of Malta, Robert Abela, said in the Malta Independent: 'Malta has implemented its ...

Malta being at the heart of the Mediterranean, is a centre of excellence in the remote gaming sector globally. There are many reasons which show Malta’s attractiveness as a jurisdiction, including a mature and professional ecosystem surrounding the gaming industry. These are just a few of the reasons as to why big brands and other players come to Malta:

1. English ...

Which companies are affected?

Large international groups of companies with an annual turnover combined financial revenues of more than €750 million are to be subject to a minimum income tax of 15 per cent from 2023. Such a tax regime would in Malta probably only affect some 18 to 20 large international players from the gaming and financial/corporate services sectors.

For all ...

In a governance note published on 9th March 2021 the MFSA has emphasised that the creation of a sound compliance culture should be the foundation upon which Company Service Providers (CSPs) build their structures.

Compliance as a top-down exercise

At Board of Directors’ level, MFSA stipulates, that this has to translate into practicing a culture of compliance and determining the means with ...

In today's business world, access to banking solutions is becoming increasingly difficult. If the client due diligence (CDD) has been successfully completed, setting up a company per se is work that requires legal and tax expertise, but through structures and guidelines of the respective company law as well as the responsible commercial register (for Malta: Malta Business Registry, MBR) based ...

Malta is still the leading international online gaming jurisdiction. With over 250 registered online gaming companies, more than 600 active licenses and over 8,000 professionals, the online gaming sector is one of the most dynamic economic sectors in Malta.

Since the law reform in August 2018, the remote gaming application process has changed:

1. Gaming licenses are now valid for 10 years
After ...

What is a PTC?

The Private Trustee Company (PTC) is a company form recognized in Malta since April 2016 having the legal nature of a limited liability company (LLC). As a trust, the purpose of the company is to manage family assets, including real estate, for the benefit of present and future generations. Similar to a will, it enables the settlement ...

The year 2020 will be a year of new beginnings for Malta; the island state is faced with the task of regaining the trust that was called into question under the old government, rebuilding its good international reputation, making its governmental and administrative structures more transparent and efficient and positioning Malta even more clearly as an international investment location.

New Prime ...