The discussion focused on how international investors and entrepreneurs residing in Portugal can use Malta’s tax framework to build efficient and fully compliant business structures within the EU.
Mr Zammit outlined the types of clients who can benefit from Maltese structures, including:
high-net-worth individuals relocating to Portugal with international business activities;
holding companies for international investments;
businesses requiring EU jurisdiction with low effective tax rates.
1. Malta’s tax advantages for foreign residents. Ivan explained that while Malta has a standard corporate tax rate of 35%, foreign shareholders may be eligible for a 6/7 refund, reducing the effective tax rate to around 5%. This makes Malta an attractive jurisdiction for international entrepreneurs.
2. Portugal—Malta tax interaction. Although Portugal and Malta do not have a double taxation agreement, Portuguese residents doing business in Malta can efficiently structure their tax liabilities through foreign tax credits, participation exemptions, and Malta’s refund mechanisms.
3. Considerations for IFICI taxpayers. Residents under the Portuguese IFICI regime, known as NHR 2.0, may benefit from exemptions on foreign-source income if certain conditions are met.
4. Compliance and risk management. Ivan highlighted the importance of real business substance in Malta — such as having an office, director services, and operational activity — along with proper transfer pricing documentation and avoiding aggressive tax strategies.
The Immigrant Invest team is planning to hold a dedicated training and Q&A session on the discussed topic with Ivan Zammit to provide deeper insights for the team and clients.
