Malta offers effective tax structures for the ownership of the intellectual property and the channelling of fees generated from licensing rights. The Malta Company is a very effective international tax-planning vehicle and is suitable for:

• licensed investment services activities;
• brokerage activities & commission income;
• management and consultancy activities;
• international trading business;
• e-commerce activities;
• licensed online gaming & betting activities;
• ownership & licensing of patents, copyrights, trademarks, franchises, domain names and other intangible assets;
• property ownership & project management;
• ownership and leasing of machinery, foreign registered motor vehicles and trucks;
• hold assets and investments of all kinds (intellectual property, real estate, shares & securities, bank accounts, etc).

Malta IP holding company receiving Passive royalties

The Income Tax Act defines “passive interest and royalties”[1] as interest or royalties income which is not derived, directly or indirectly, from a trade or business, and

1. such interest has not suffered any foreign tax, or
2. such interest has suffered foreign tax, directly, by way of withholding or otherwise, lower than 5%.

Tax refunds on passive royalties income

Shareholders of IP holding companies receiving passive interest income benefit from a 5/7ths refund of Malta tax suffered by such IP holding company, effectively a refund of 25%.