Malta Offshore Company Formation in 2026

A Malta company owned and run from abroad gives you an EU company in the eurozone, access to around 80 tax treaties and no withholding tax on dividends paid to non-resident shareholders. Through the shareholder refund, tax on trading profits comes down to about 5%.

The catch is that Malta is not a classic offshore jurisdiction. Its offshore regime closed to new companies at the end of 1996. Every Malta company now pays 35% first, the refund only follows a dividend and can be delayed, and banks and tax authorities ask where the company is really managed.

This is where we come in. We handle your Malta offshore company formation from start to finish: the structure and the refund plan, the memorandum, the ownership forms, the filing and the bank file. One team, one clear price from €1,299, no back-and-forth emails, and the company is formed in about a week.

Looking for a zero-tax company outside the EU? Read our guide to BVI offshore company formation.

Why Set Up an Offshore Company in Malta

Founders choose offshore company formation in Malta for a low effective tax rate inside the EU. Trading profits are taxed at about 5% after the shareholder refund, dividends leave Malta without withholding tax, and holding income can be fully exempt. The company is an ordinary EU company that banks, customers and tax authorities recognise.

About 5% Tax on Trading Profits

A Malta company pays 35% tax on its profits. When it pays a dividend, the shareholder can claim back six-sevenths of the tax paid on trading profits, so the net Malta tax is about 5%. Non-resident shareholders can claim the refund, and the refund itself is not taxed in Malta.

No Tax on Dividends Paid Abroad

Malta charges no withholding tax on dividends paid to non-resident shareholders out of taxed profits. Interest and royalties paid to a non-resident are also exempt, as long as they are not tied to a business in Malta and the recipient is not owned or controlled by people ordinarily resident and domiciled in Malta.

An EU Company in the Eurozone

Malta joined the EU on 1 May 2004 and the euro on 1 January 2008, and it removed its last capital controls when it joined the EU. A Malta company uses the EU directives on parent and subsidiary dividends, trades with an EU VAT number and pays its suppliers in euro through SEPA.

Around 80 Tax Treaties

Malta has concluded around 80 double tax treaties. A treaty can cut the foreign tax on dividends, interest and royalties that flow into the Malta company, and it gives both countries rules on where the company is resident. Treaty access depends on the company being managed in Malta, which is why management matters so much for a Malta offshore company formation.

A Holding Regime With Full Refunds

Dividends and gains from a participating holding can be exempt in Malta, or carry a full refund of the Malta tax paid. This makes Malta a common choice for European holding company formation. Our guide on how to set up a Malta holding company covers the conditions.

One Owner Is Enough

A private exempt company can have a single shareholder, and its sole director can also act as company secretary. A one-person Malta company needs no nominee and no second officer, as long as it meets the exempt conditions in its memorandum.

Is Malta an Offshore Jurisdiction

No. Malta is an EU member state with full tax transparency, and its offshore company regime was closed decades ago. What people now call a Malta offshore company is an ordinary Malta company owned and run from abroad, which pays 35% tax and uses the shareholder refund to reach a low effective rate.

Malta's Offshore Regime Ended in the 1990s

Malta introduced offshore companies under the Malta International Business Activities Act, passed in 1988 and in force from 1989. New offshore companies could only be registered until the end of 1996, and the regime was phased out by 2004, with existing companies converting to the onshore regime or being dissolved.

The Trading Company Regime Ended in 2010

Malta then offered international trading companies a refund regime of their own. In March 2006, the European Commission asked Malta to abolish it under the EU state aid rules, and the regime ended on 31 December 2010. Today the same refund system applies to every Malta company, whoever owns it. That is why offshore company formation in Malta is now ordinary company formation.

What Offshore Means in Malta Today

A company incorporated in Malta after 1 July 1994 is resident in Malta and taxed on its worldwide income. Its owners are recorded in the beneficial ownership register, its accounts are filed publicly, and Malta has exchanged financial account information under the Common Reporting Standard since 2017, as an early adopter. Offshore company formation in Malta gives you a low-tax company, not a secret one. Our guide to offshore vs onshore companies explains the difference.

Malta and the EU Tax Lists

Malta is not on the EU list of non-cooperative jurisdictions for tax purposes. The list was last updated on 17 February 2026 and names 10 jurisdictions, including Panama, Russia, Vanuatu and the US Virgin Islands. Malta's participation exemption does not apply to holdings in a listed jurisdiction unless the company shows enough substance, so check every subsidiary's country before you rely on it.

Malta Offshore Company Tax

Malta offshore company tax starts at the standard 35%. The shareholder then claims a refund when a dividend is paid, which brings the net Malta tax to about 5% on trading profits, about 10% on passive interest and royalties, and nothing on qualifying holding income. Since 2025, a company can elect a final 15% tax instead.

Malta offshore company tax depends on what the company earns, not on who owns it. Trading companies get the lowest rate on active income, holding companies get a full refund or an exemption on qualifying dividends, and property income in Malta gets no refund at all. Plan the activity before you plan the rate.

How the Shareholder Refund Works

The company pays its tax, then pays a dividend. The shareholder claims the refund, and it becomes due once the company's tax return is filed, the tax is paid and a complete claim is made. The Commissioner must pay it within 14 days, but the law lets that period be extended by up to 12 months where further checks are needed. Claims must be made within four years. Refunds can never exceed the tax the company actually paid.

Final Tax of 15% Instead of Refunds

Since the Final Income Tax Without Imputation Rules of 2025, a company can elect a final tax of 15% on its income, through its tax return, by the online filing deadline. There are no refunds, and dividends paid from those profits carry no further tax. The election binds the company for at least five years, and the 15% can never be lower than the ordinary tax after refunds. It suits companies that keep their profits in the business, because the refund route only pays out when a dividend is paid.

Participation Exemption for Holding Companies

A holding is a participating holding if the Malta company owns at least 5% of the equity with matching rights, or has invested at least €1,164,000 and held it for 183 days, among other tests. For holdings in companies outside the EU, the subsidiary must also meet an anti-abuse test, such as being taxed at 15% or more abroad, or earning no more than half its income from passive interest and royalties.

Notional Interest Deduction

A company funded with equity can claim a notional interest deduction under rules in force since 2018. The rate is the yield on 20-year Malta government stocks plus 5%, and the deduction is capped at 90% of chargeable income. It is useful for well-capitalised trading and finance companies.

Pillar Two and Large Groups

The EU minimum tax of 15% applies only to groups with consolidated revenue of €750 million or more. Malta has deferred the main Pillar Two rules until 31 December 2029 and has no domestic top-up tax, so the refund system still works for most groups, and small founders are not affected at all.

Read more: how to use an offshore company for tax planning and Malta tax accounting rules for companies.

Malta Offshore Company Formation for Non-Residents

Malta offshore company formation works fully for non-residents. Malta sets no residency rule for shareholders, directors or the company secretary, documents are signed with qualified e-signatures and the company is filed online. The questions that matter are where the company is managed and how the owner's home country treats it.

No Residency Rule for Owners or Directors

A private company needs at least one director and a company secretary, and none of them has to live in Malta. A company can be a shareholder too. The company must have a registered office in Malta, which our partners provide from €900 + VAT a year.

Filing From Abroad

New companies are filed only online, through the Registry's BAROS system, since 1 March 2025. Filing yourself needs a Maltese e-ID or an EU eIDAS login, so most founders outside the EU file through a licensed provider. Non-EU shareholders also give a bank or professional reference letter dated within six months.

Home Country Rules

Many countries tax their residents on the profits of a low-taxed foreign company they control, under controlled foreign company rules. Every EU country has such rules. Check your own position before offshore company formation in Malta, because a Malta refund does not stop your home country from taxing you.

Types of Offshore Company in Malta

Most offshore company formation in Malta uses a private limited company, set up as a trading company, a holding company, or a holding company above a trading company. Each type gets a different tax result from the refund system, so the choice decides your effective rate.

Trading Company

A trading company earns active income, such as services, software, sales or consulting. It pays 35% and its shareholders claim six-sevenths back, for about 5% net. It usually registers for VAT and has more transactions, so its yearly accounting costs more.

Holding Company

A holding company owns shares in other companies. Dividends and gains from participating holdings can be exempt or carry a full refund. It suits founders who own several companies or plan to sell one. See our guide to holding company vs operating company for how the two roles differ.

Holding and Trading Group

Many founders use two Malta companies: a trading company that pays the tax, and a holding company above it that receives the dividend and claims the refund. The refund then stays inside the group until the owner needs it. Each company needs its own capital, filings and account.

Single Member Company

A private exempt company can have one shareholder, and its sole director can also be secretary. It must name its main activity in its objects and notify the Registry within 14 days when it becomes, or stops being, a single member company.

Licensed and Special Structures

Gaming, payments, crypto and investment companies need a licence on top of the company, and SPVs, trusts and foundations need their own documents. These are quoted separately. See our guides to special purpose vehicles in Malta and setting up a trust in Malta.

How to Set Up an Offshore Company in Malta

How to set up an offshore company in Malta comes down to a few steps that we run for you: plan the tax route and the management, choose the structure, build the KYC file, pay in the capital, file with the Registry, register for tax and VAT, and open the account. With a complete file, it takes about a week.

Before You Start

Decide two things first. Will the company pay dividends each year and use the refund, or keep its profits and use the final 15% tax? And where will the board meet and decide? These two answers shape the documents, the bank file and the yearly costs of the company.

Choose the Structure

We confirm the company type, the shareholders, the directors and the secretary, and whether you need one company or a holding company above a trading company. We check the activity and the countries against Maltese law and against our banking partners' rules before anything is filed.

Build the KYC File

Every director, shareholder and beneficial owner provides a certified passport copy and a proof of address under three months old. A company shareholder adds its certificate of good standing and register extract. We prepare the ownership chart and the source of funds documents at the same time.

Pay In the Capital

A private company needs authorised capital of at least €1,164.69, with 20% of each share, €232.94 at the minimum, paid when the memorandum is signed. The Registry asks for a bank receipt showing the name of the company in formation, and we arrange this step with you. The capital can be in any convertible currency.

File With the Registry

We draft the memorandum and articles, collect the directors' consent forms and file everything online with the beneficial ownership declaration. The Registry fee is €100 for authorised capital up to €1,500, included in our price. A complete file can be registered within 24 hours.

Register for Tax and VAT

The tax number is issued automatically on registration. VAT is a separate step: Article 10 for most trading companies. A pure holding company usually does not register for VAT.

Open the Account

Our banking partners open a multi-currency account online, usually within 2 to 4 business days of registration. Our guide on how to set up a Malta company with a bank account covers this step in detail.

Documents Needed for a Malta Offshore Company

The documents needed for a Malta offshore company cover every person behind it, any company that owns it and the business it will run. Certification matters as much as the list, because one missing stamp sends a file back.

For Each Owner, Director and Signatory

A certified copy of a valid passport, a proof of address under three months old and, for non-EU shareholders, a bank or professional reference letter dated within six months. Each director also signs a consent and declaration form dated within one month of filing.

For a Company Shareholder

A certificate of good standing, a register extract showing the directors and shareholders, the constitutional documents and a board resolution approving the investment. The ownership chart must show every level up to the individuals at the top.

For the Business and the Bank

A short description of the activity, the main countries and the expected turnover, plus documents for the source of funds behind the capital and the first deposit. Documents issued outside Malta often need an apostille, and anything not in English needs a certified translation.

Read more: Malta company formation requirements and how to open an offshore company as a non-resident.

Malta Offshore Company Formation Cost in 2026

Malta offshore company formation starts from €1,299 with us for a standard limited company. A realistic first year, with the office, secretary, accounts, tax return and a bank account, is about €6,800 to €10,500 plus VAT for a small company.

Our price covers the structure advice, the KYC file, the memorandum and articles, the ownership forms, the Registry fee and the filing, confirmed in writing before you pay. Trusts, foundations, cell companies and licensed structures are quoted separately and can cost more. The yearly services come from our partners.

The yearly services are the larger part of the bill. Offshore company formation in Malta should save more in tax than the company costs to run, so a company with small profits may not justify the yearly fees. Our guide to how much a Malta company costs has every line.

First-Year Cost by Company Profile

Whatever the profile, our formation price stays the same: from €1,299 for a standard company.

How Long Malta Offshore Company Formation Takes

Malta offshore company formation takes about a week with us, from the first call to the certificate of registration. The Registry can register a complete file within 24 hours, so most of the week goes on the KYC documents. The bank account usually follows within 2 to 4 business days.

What Takes the Time

Certified copies, proofs of address, the reference letter for non-EU shareholders and apostilles for documents from abroad take longest. A company shareholder adds its good standing certificate and register extract. Order these first.

When the First Refund Arrives

The refund comes much later than the company. It follows the first dividend, the filing of the company's tax return and a complete claim, so the first refund on a trading company usually arrives in its second year. Budget for the full 35% until then.

Compliance for a Malta Offshore Company

Every Malta offshore company has the same yearly duties as any Malta company: an annual return, financial statements, a tax return, refund claims after dividends and prompt filings when owners or officers change. Most of this is the company secretary's and the accountant's job.

A small private company within two of three limits (balance sheet €46,600, turnover €93,000 and two employees) is exempt from the Companies Act audit, and under the Audit Exemption Rules 2025 it can file a cheaper review report for tax, or nothing at all if it is within all three. Holding companies with large balance sheets usually still need an audit. See our pages on audit services for Malta companies and how to file a Malta company tax return.

Records and Registers

The company keeps its register of members, minutes, beneficial ownership register and accounting records, and keeps the accounting records for 10 years. Since July 2026, a company owned only by individuals, with no trustee or hidden owner, can use its register of members as its ownership register.

Reporting to Other Countries

Malta exchanges financial account information under the Common Reporting Standard, so accounts held by the company and its owners abroad are reported to the owners' home tax authorities. Plan for transparency, not secrecy. Our guide to the Malta annual return and beneficial owner confirmation covers the yearly filing.

Substance and Management of a Malta Offshore Company

After offshore company formation in Malta, the company is resident in Malta because it is incorporated there, but other countries look at where it is managed. If every decision is made in your home country, that country may treat the company as its own resident and tax it. Real management in Malta protects the treaty position and makes the bank file easier.

Board Meetings and Decisions

Hold board meetings in Malta or with directors who are in Malta, keep minutes that show the decisions, and sign important contracts there. A company whose directors all live in one other country, and decide everything there, is the hardest to defend.

A Maltese Director

A local director supports Maltese management and helps with banks. Through our partners, a corporate director starts from €1,500 + VAT a year and an individual director from €2,000 + VAT. An exempt company cannot have a corporate director, so plan this at formation. See our page on company director services in Malta.

Substance the Bank Will Ask About

Banks ask what the company does, where its customers and suppliers are, who runs it and where the money comes from. A Malta company with a real activity, a local director or staff and a clear ownership chart opens accounts faster than a company that exists only on paper.

Business Banking for a Malta Offshore Company

Every Malta offshore company needs an account in its own name to pay dividends, receive refunds and trade. Maltese banks treat a company owned from abroad as a higher-risk client: HSBC Malta charges a company 50% or more owned by a parent outside Malta €175 a month as an International Company, BNF Bank charges international corporate customers €1,500 a year per account, and reviews take weeks or months.

The Faster Route Through Our Partners

Our banking partners are licensed e-money institutions, regulated in the EU and the UK. They open multi-currency accounts online in days, with no branch visit, no minimum balance and the same plan whoever owns the company, from €30 to €100 a month. We prepare the bank file during formation, so the account can open soon after the certificate. Our guide on how to open an offshore bank account in Malta covers both routes.

Malta vs Cyprus, the BVI and the UAE

Founders who look at offshore company formation in Malta usually compare it with Cyprus, the British Virgin Islands and the UAE. Cyprus is the other EU low-tax option, while the BVI and the UAE offer lower headline rates outside the EU.

Malta gives the lowest effective rate on trading profits inside the EU, but it asks you to pay 35% first and wait for the refund. Cyprus is simpler, at one flat rate. The BVI and the UAE are lower still, but they sit outside the EU and bring their own banking and substance questions.

Malta vs Cyprus

A Cyprus company pays a flat 15% since January 2026, with no refund step, so cash flow is simpler, but every Cyprus company needs an audit. Malta wins on trading profits once the refund is paid. See our guide to holding company formation in Cyprus.

Malta vs the BVI

A BVI company pays no corporate tax and forms in 2 to 5 working days, but it is outside the EU, has no treaty network to speak of and is harder to bank with EU banks. It suits pure holding structures more than trading companies. See our BVI company formation guide.

Malta vs the UAE

A UAE company pays 0% on profits up to AED 375,000 and 9% above, and qualifying free zone companies can pay 0%. It suits founders who live in or trade with the Gulf. Malta suits founders whose customers are in the EU. See our guide to offshore company setup in the UAE.

Who a Malta Offshore Company Is Wrong For

A Malta offshore company is wrong for founders who want a zero-tax company with no reporting, because Malta is fully transparent and every company pays 35% before any refund. It is also a poor fit for very small companies, where the yearly costs of about €6,800 or more outweigh the tax saving.

It does not suit companies whose main income is property in Malta, which gets no refund, or owners whose home country will tax the profits anyway under its controlled foreign company rules. It needs care for companies that keep their profits and never pay dividends, because the refund only comes with a dividend, and the final 15% tax may then be the better route. If you only need a company to hold assets with no activity, a simpler jurisdiction may cost less to run. Our guide to the best offshore company jurisdictions compares the options.

Common Mistakes in Offshore Company Formation in Malta

Most mistakes in offshore company formation in Malta come from treating it like a classic offshore company. These are the ones that cost founders the most.

Budgeting at 5% From the First Day

The company pays 35% first, and the refund only arrives after a dividend, a filed tax return and a complete claim. It can be delayed by up to 12 months for checks. A company that plans its cash at 5% can run short in its first year. Budget for the full 35% until the first refund is in.

Running the Company From Home

A Malta company whose directors decide everything in another country can be treated as resident there and taxed on its profits. Hold board meetings in Malta or with directors there, keep proper minutes and consider a Maltese director.

Expecting Secrecy

Owners are recorded in the beneficial ownership register, accounts are filed and financial accounts are reported under the Common Reporting Standard. A structure built to hide owners will fail at the Registry and at the bank.

Electing the Final 15% Tax Without Checking

The final 15% tax binds the company for at least five years. For a trading company that pays dividends every year, the refund route gives about 5%, so the final tax can cost three times more. Run the numbers for your own profits and dividends before you elect.

Missing Refund Claims

A refund claim must be made within four years. Companies that pay dividends but never file the claims, or file them with incomplete certificates, lose money they were owed. Put the claims in the calendar with the tax return.

Bottom Line

Malta is not a zero-tax offshore centre. Malta offshore company tax starts at 35%, and the shareholders of a company owned from abroad claim most of it back, for about 5% on trading profits and nothing on qualifying holding income. Dividends leave Malta without withholding tax, and the company sits inside the EU with around 80 tax treaties.

The trade-off is cash flow, transparency and management. Plan the refunds, hold the board in Malta and keep the records clean. We handle Malta offshore company formation from €1,299, with the office and secretary from our partners and the bank file ready when the company is formed.

Sources

• Income Tax Act, Cap. 123
• Income Tax Management Act, Cap. 372
• Final Income Tax Without Imputation Rules, L.N. 188 of 2025
• MTCA, election for final income tax without imputation, March 2026
• Notional Interest Deduction Rules, S.L. 123.176
• Companies Act, Cap. 386
• Malta Business Registry, formation and registration
• Audit Exemption Rules 2025, L.N. 139 of 2025
• MTCA, DAC2 and the Common Reporting Standard
• Council of the EU, EU list of non-cooperative jurisdictions
• University of Malta, From MIBA to MFSC, 1999
• Central Bank of Malta, our history