Malta Limited/Ltd Incorporation/Formation/Setup + Maintenance

[blast629]

Hi there!!

Related to this post of my own, I am trying to find the best ways to get around the different alternatives, one of them being the IFICI (the NHR 2.0). It seems like the MT Ltd can be attractive because of the low 5% CIT, but i think the main deal for low incomes is the high costs of running MT companies.

I am looking into get how much could be the full incorporation: Registry, incorporation documentation/notary fees, bank setup, etc etc ; as well as the recurring costs: accountancy, annual filing fees, nominee director, virtual office, etc etc.

I have been exploring the forum, and as of now, the only thing i got clear is that this: https://www.millionmakers.com/virtual-office/virtual-office-santa-venera/ is a cheap virtual office alternative, but still somewhat lost on the rest.

Do any of you have any idea of what is the landscape like in this topic? Any broad numbers you may know?

Also, in case any of you of any local law/tax firm for accountants/lawyers, would be great.

Thank you all!

 

[Marzio]

blast629 said:
Any broad numbers you may know?
Click to expand...

Don't expect anything less thank 10K/year

Do i need to remember you are making 80K / year?

Unless you foresee to skyrocket your income to at least 500K / year this structure DOES NOT MAKE any financial sense.

You are paying 12.5% of your income for the the privilege of paying 5% taxes.

You are paying 17.5% taxes in Malta with operating and holding company

US LLC + non-dom = 6,25% total

 

[blast629]

Marzio said:
Don't expect anything less thank 10K/year

Do i need to remember you are making 80K / year?

Unless you foresee to skyrocket your income to at least 500K / year this structure DOES NOT MAKE any financial sense.

You are paying 12.5% of your income for the the privilege of paying 5% taxes.

You are paying 17.5% taxes in Malta with operating and holding company

US LLC + non-dom = 6,25% total
Click to expand...

You are right. If those are the costs it 100% make no sense to take the hassle.

By the way, the idea for this is to be paired with NHR more than with non dom. I think it is safer to run the US LLC on Malta than on PT because the Tax Authorities being more laxative?

I guess smaller firms may be more affordable though. And basically that is what I was looking for, if maybe there was a setup not really costing more than 3-4k per year, which could be worth the extra safety in my opinion...

But 15k is totally crazy for sure

Thanks Marzio!

 

[shimo]

Marzio said:
Don't expect anything less thank 10K/year

Do i need to remember you are making 80K / year?

Unless you foresee to skyrocket your income to at least 500K / year this structure DOES NOT MAKE any financial sense.

You are paying 12.5% of your income for the the privilege of paying 5% taxes.

You are paying 17.5% taxes in Malta with operating and holding company

US LLC + non-dom = 6,25% total
Click to expand...

6,25% , untill 2026..
It is highly likely new tax reform will be taking place; CIT rise already confirmed.

 

[JustAnotherNomad]

How do you arrive at 6.5%?

 

[blast629]

shimo said:
6,25% , untill 2026..
It is highly likely new tax reform will be taking place; CIT rise already confirmed.
Click to expand...

How would that affect? The 6.25% is non-dom related.

I guess you mean the 5% effective CIT for Maltese corporations is going to change?

JustAnotherNomad said:
How do you arrive at 6.5%?
Click to expand...

I think he means with non-dom you pay 5k for everything above to 35k to Maltese Tax Authorities.

With the LLC you would pay no more than that, since they treat them as opaque entities.

Therefore 5.000/80.000 = 6.25%

The idea of the Maltese Ltd is because in PT with NHR/IFICI is somewhat safer than the LLC. But of course, if the costs are too high, pretty much makes no sense, and it is better to take the risks... I guess that is what @Marzio mean

Thank you all

 

[shimo]

blast629 said:
How would that affect? The 6.25% is non-dom related.

I guess you mean the 5% effective CIT for Maltese corporations is going to change?

I think he means with non-dom you pay 5k for everything above to 35k to Maltese Tax Authorities.

With the LLC you would pay no more than that, since they treat them as opaque entities.

Therefore 5.000/80.000 = 6.25%

The idea of the Maltese Ltd is because in PT with NHR/IFICI is somewhat safer than the LLC. But of course, if the costs are too high, pretty much makes no sense, and it is better to take the risks... I guess that is what @Marzio mean

Thank you all
Click to expand...

Non-dom schemes highly likely from 2026 will face a €5K/year minimum fee, stricter CFC rules, reduced NHR/IFICI benefits, increased transparency, and high risk of US LLCs managed by Cyprus Ltd being reclassified as EU tax residents without proper substance.

 

[blast629]

shimo said:
Non-dom schemes highly likely from 2026 will face a €5K/year minimum fee, stricter CFC rules, reduced NHR/IFICI benefits, increased transparency, and high risk of US LLCs managed by Cyprus Ltd being reclassified as EU tax residents without proper substance.
Click to expand...

What is this info based on? Any EU new regulations?

Looking forward to know more

 

[Marzio]

blast629 said:
Therefore 5.000/80.000 = 6.25%
Click to expand...

Correct.

shimo said:
managed by Cyprus Ltd
Click to expand...

Dude, we are talking about Malta

 

[dziter]

blast629 said:
Non-dom schemes highly likely from 2026 will face a €5K/year minimum fee
Click to expand...

If you are speaking about Cyprus, there is a thread speaking about new upcoming (potential) rules here:
https://www.offshorecorptalk.com/threads/cyprus-new-15-cit-5k-non-dom-fee.47395/

However, there is no serious source about the non-dom fee you are mentioning. If you have one, please share it.

 

[blast629]

dziter said:
If you are speaking about Cyprus, there is a thread speaking about new upcoming (potential) rules here:
https://www.offshorecorptalk.com/threads/cyprus-new-15-cit-5k-non-dom-fee.47395/

However, there is no serious source about the non-dom fee you are mentioning. If you have one, please share it.
Click to expand...

I was just quoting the other mate. I have no clue about what he meant for 2026...

Just know the current rules as of today

 

[dziter]

dziter said:
If you are speaking about Cyprus, there is a thread speaking about new upcoming (potential) rules here:
https://www.offshorecorptalk.com/threads/cyprus-new-15-cit-5k-non-dom-fee.47395/

However, there is no serious source about the non-dom fee you are mentioning. If you have one, please share it.
Click to expand...

@shimo : What is your source?

 

[aragon]

Marzio said:
Don't expect anything less thank 10K/year
Click to expand...

How do you reach this figure?

In my experience a Malta company can be maintained for about €2.2k per year. That includes audit, tax return, legal address, and annual return. Add a UK holding for about €300 per year.

 

[vs90]

blast629 said:
I think he means with non-dom you pay 5k for everything above to 35k to Maltese Tax Authorities.

With the LLC you would pay no more than that, since they treat them as opaque entities.

Therefore 5.000/80.000 = 6.25%
Click to expand...

This works only if management and control are NOT in Malta. If they are, Maltese Tax Authorities will treat that income as Maltese earned, and not as a foreign dividend.

It looks to me that it's quite unlikely they will find out if it's never remitted, and you can sustain your cost of living with a local salary and/or foreign remitted capital gains.

However, it's still not a clean setup and, if, for some reason, they find out, you will end up paying the 35% CT + interest + penalties, which might as well be 50% of the income.

Please, someone correct me if I'm wrong; that's my understanding.

 

[Marzio]

aragon said:
How do you reach this figure?
Click to expand...

I was quoted 10.690€ for a holding & trading company from a Maltese fiduciary

 

[lacomaco]

shimo said:
Non-dom schemes highly likely from 2026 will face a €5K/year minimum fee, stricter CFC rules, reduced NHR/IFICI benefits, increased transparency, and high risk of US LLCs managed by Cyprus Ltd being reclassified as EU tax residents without proper substance.
Click to expand...

The €5k non-dom minimum tax has been in force for at least 3 years now... I am not sure what source told you that it would come in 2026 but surely they are wrong

 

[blast629]

aragon said:
How do you reach this figure?

In my experience a Malta company can be maintained for about €2.2k per year. That includes audit, tax return, legal address, and annual return. Add a UK holding for about €300 per year.
Click to expand...

That is not bad!! May I know which the firm is so I may get in touch with them? What were the formation costs?

Also, do you know by any means what a nominee director could be the cost?

And what do you use the UK holding for?

vs90 said:
This works only if management and control are NOT in Malta. If they are, Maltese Tax Authorities will treat that income as Maltese earned, and not as a foreign dividend.

It looks to me that it's quite unlikely they will find out if it's never remitted, and you can sustain your cost of living with a local salary and/or foreign remitted capital gains.

However, it's still not a clean setup and, if, for some reason, they find out, you will end up paying the 35% CT + interest + penalties, which might as well be 50% of the income.

Please, someone correct me if I'm wrong; that's my understanding.
Click to expand...

I think that is right, however, as you said it is very unlikely they will get to know.

What would the alternative though? A nominee director for the LLC?

Marzio said:
I was quoted 10.690€ for a holding & trading company from a Maltese fiduciary
Click to expand...

Wow! That is a huge amount of money! I guess that is why you recommended me to look for an alternative. 2k is very different though!

lacomaco said:
The €5k non-dom minimum tax has been in force for at least 3 years now... I am not sure what source told you that it would come in 2026 but surely they are wrong
Click to expand...

So it is just what there is already in force right? The 5k for everything above 35k?

Thank you all!

 

[bubbledouble]

Marzio said:
Don't expect anything less thank 10K/year

Do i need to remember you are making 80K / year?

Unless you foresee to skyrocket your income to at least 500K / year this structure DOES NOT MAKE any financial sense.

You are paying 12.5% of your income for the the privilege of paying 5% taxes.

You are paying 17.5% taxes in Malta with operating and holding company

US LLC + non-dom = 6,25% total
Click to expand...

You say he would be able to do the same with the US LLC and a non dom company? where does this NON DOM company need to be for this to work ?