Global Daily Tax News, Malta Introduces Alternative 15pc Corporate Tax Regime, (Sep 12, 2025)

The Maltese Government has enacted the Final Income Tax Without Imputation Regulations, 2025.

The Regulations provide for an alternative to Malta's standard corporate income tax regime – the full imputation system – enabling taxpayers to be taxed under traditional corporate tax rules at a 15 percent rate.

The Regulations provide that tax chargeable under the flat corporate income tax regime may not be lower than the rate under the imputation system, after taking into account refunds for shareholders.

The regulation provides that the tax charged under the 15 percent final corporate tax regime will be final and not available as a credit or deduction against the tax liability of any individual or entity, or as a refund to any person.

The regime is available both to corporates as well as trusts liable to corporate tax.

The regime may be applied to the year prior to the 2025 year of assessment. An election to be taxed under the final 15 percent corporate income tax regime is binding for five years.