Malta's new offer for smaller structures and start-ups: 15 percent final corporate tax without a holding company

Legally secure emigration from Germany within the EU

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 to for at least five years.

The Fiscal Unit Model with 5% corporate tax remains the standard.

Malta is known for its consolidation system: foreign shareholders can reduce their effective tax burden to 5% via a Malta holding structure. This requires at least two companies, a holding company and an operational trading company, which form a so-called fiscal unit, within which the holding company becomes the main taxpayer by filing a consolidation tax return.

Due to the requirement for at least two companies, the start-up and maintenance costs are slightly higher; on the other hand, the tax is 10 percentage points lower, making it significantly cheaper for larger structures.

15% final tax for smaller structures and self-employed persons with a company

With the new 15% final tax model, entrepreneurs can opt for a simpler structure with a final tax burden of 15% without having to set up multiple companies for tax purposes.

A potential advantage for start-ups

The new and alternative model (tax consolidation remains the norm) may be of interest to founders and entrepreneurs who are just starting out:

• In the first few years after founding, profits are often low.
• In certain cases, the effort involved in setting up a holding structure is not economically viable.

Especially in the first five years – when growth is more important than tax optimisation – the final tax can be attractive under certain circumstances.

Two models for practice – Malta's business-friendliness is attracting more and more entrepreneurs from German-speaking countries.

Malta is thus skilfully positioning itself in international competition: Those who focus on initial cost savings with an expected annual profit of less than EUR 100,000 will find the 15% final tax a cost-effective and simple structure. On the other hand, those who expect profits significantly above EUR 100,000 will opt for the consolidation model with a corporate tax rate of 5%, which is unique in Europe.

Contact Dr. Kresse International Group: with competent German advocates who are based in Malta and registered and licensed here as European lawyers, you have the best expert partners in terms of legally and fiscally secure company structures and their professional support, following our initial and free initial consultation.