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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Malta: Maltese International Business Companies

The Malta International Business Activities Act 1988 confers certain tax benefits on non-Maltese resident companies engaged in offshore banking, insurance or general trading activities and those limiting their objectives to the ownership, management and administration of any kind of property.

A company which is entitled to a special tax benefit under the Act is outside the scope of the agreement unless it has made an irrevocable election under Section 41 of the Act to waive the benefit and to be subject to the normal provisions of the Malta Income Tax Act. A company making such an election will subsequently be entitled to claim the reliefs available under the agreement, those companies not so electing will not be able to claim any reliefs available under the agreement.