Malta 5% scheme structure formation

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yes, there is a declaration form CT2 that needs to be filed. Does not look‍ so bad, to be honest. Wondering if I should just push back on the accountant.⁠
 
CFC rules‌ dont come into play here. The company would be deemed Maltese tax resident but non-domiciled‍ in Malta. No tax is payable on foreign income which is not received in Malta⁠ and on capital gains arising outside Malta. At least this has been my understanding when⁤ having dealt with this jurisdiction.
 
You are most likely correct, the offshore company is not a CFC since it’s already‌ tax resident in Malta.
 
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