You mean no dividends are being paid at all? Because if you are not paying dividends to UK shareholder then you are not paying out dividends to anyone else right as that would not be possible right?
Malta Tax Rebate 6/7
- Thread starter Jay Hastings
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As my accountant made last year the refund is made directly on the bank account of the malta ltd or to the beneficial owner resident non dom... last year i’ve got smoothly in this way let s see this year...
Btw tomorrow or Monday i’ll get a call from csb about cfc rule, refund 6/7 etc...
Btw tomorrow or Monday i’ll get a call from csb about cfc rule, refund 6/7 etc...
Well if your not paying out any dividends then the UK company carries out no activity whatsoever and serves no purpose. This then is 100% a purely artificial tax avoidance structure that has been created to lower the taxes of a Malta resident non-dom.︀ It may be legal in Malta (where anything flys) but is 100% an artificial construct︁ that you have where you derive a tax benefit conf/(%.
Yes could be but if you think more deeply, we are talking about an holding , how many decision the Director of the holding take annually??? 2/3 flights to UK︀ maybe? So in fact company is not managed and controlled in Malta! And in Fact︁ maltese company is holding by foreign shareholder.
Why bother thinking about this as the UK company receives no dividends and has no activity whatsoever hence no tax liability will be possible. Remember the UK company has the sole purpose of achieving an artificial tax advantage in Malta for its Malta subsidiary. You, I and your Malta accountant all know the UK company is just a place holder for tax purposes of the Malta company....lol. So what︀ has any of the above got to do with your situation.
Your Malta company is a subsidiary of the︃ UK company i.e it is 100% owned by the UK company is it not? conf/(%
Your Malta company is a subsidiary of the︃ UK company i.e it is 100% owned by the UK company is it not? conf/(%
yes 100% own of the uk ltd
today i will have a︁ call with few accountant, let's see... but all accountants ask to the CFR how to︂ proceed.
my accountant too work in this industry from 15 years, she is confronting with︃ other colleagues about tax matters so i think this is how malta work. i never︄ hear in Malta or Read on newspaper of artificial holding company to get refunds... obviously︅ because 95% of holding company that hold a Maltese company are like i've described and︆ like 100% of accountat show me.....
i simply think that in the world there are︇ not only laws but also custom (customary)
today i will have a︁ call with few accountant, let's see... but all accountants ask to the CFR how to︂ proceed.
my accountant too work in this industry from 15 years, she is confronting with︃ other colleagues about tax matters so i think this is how malta work. i never︄ hear in Malta or Read on newspaper of artificial holding company to get refunds... obviously︅ because 95% of holding company that hold a Maltese company are like i've described and︆ like 100% of accountat show me.....
i simply think that in the world there are︇ not only laws but also custom (customary)
You mean the Maltese never refer to their setup as artificial? That would be like Trump referring to himself a as liar smi(&%. The setup is very profitable for Malta. EU has already said it is not a harmful tax practice but it has no real volume to be a threat yet ns2.
Get a tax ruling from Commissioner and if given then issue is closed thu&¤#. Remember....
Get a tax ruling from Commissioner and if given then issue is closed thu&¤#. Remember....
This is because no one would use Maltese companies if they would enforce anti-abuse provisions. Malta has nothing to offer besides remittance basis of taxation and 5% tax, their general rules are quite unattractive. The only thing one would not want is for them to start enforcing retroactively.
So you did pay dividends then? The dividends have to be paid to shareholders of a company i.e UK holding company.
So did your accountant enter this dividend distribution on the accounting of the UK company? Or as you mentioned did they just file a zero return for UK company hence they committed accounting fraud? eek¤%&
So did your accountant enter this dividend distribution on the accounting of the UK company? Or as you mentioned did they just file a zero return for UK company hence they committed accounting fraud? eek¤%&
I ve explained 4 times... no bank transactions for dividend so no money in UK bank account of the holding. Accountant make all the paper for the refund... such as letters meeting of the directors and shareholders where the shareholders declare that the holding︀ got dividends and the request to the malta CFR for refund it s simple but︁ if you want know clearly how to do you can call any accountant in Malta︂ and ask them
Who said anything about bank transactions. So you make a dividend payment to UK shareholding company without recording it anywhere in UK company accounting is that correct? If so that's accounting fraud is it not?
So how then is dividend delivered to UK company and in what form and how is it recorded on UK company accounts filing?
I am trying to understand the accounting here. Because what you have said is that in Malta a wholly owned subsidiary (Malta︀ company) can announce a dividend and not pay to shareholders (UK Holding company) the dividend︁ in whatever form but instead pay to the beneficial owner instead as below right? conf/(%
P.S Dividends paid but never to︄ holding company how does that work legally in Malta?
So how then is dividend delivered to UK company and in what form and how is it recorded on UK company accounts filing?
I am trying to understand the accounting here. Because what you have said is that in Malta a wholly owned subsidiary (Malta︀ company) can announce a dividend and not pay to shareholders (UK Holding company) the dividend︁ in whatever form but instead pay to the beneficial owner instead as below right? conf/(%
P.S Dividends paid but never to︄ holding company how does that work legally in Malta?
All as i wrote... this︂ is how work the accountant in malta, and i can assure you that i ve︃ got a refund... so i dont know... i m not an accountant, all is managed︄ from my accountant if you need to know specific things you can pay an accountant︅ and talk with him
because i'm not an accountant and i don't know the procedures, i'm only sure that the dividend are not paid to the foreign company (holding), i'm sure that my accountant fill all the documents for refund because i've already got a tax refund of 6/7, and i'm sure that the Uk holding not have tax statement because it hasn't transactions. that's all.
btw i've had a call with another maltese auditor he told me that this way is very popular in malta, there are no problem, he personally are using BVI with bank account but he told me a lot of accountant are doing with UK︀ ltd without account and without problems...
btw i've had a call with another maltese auditor he told me that this way is very popular in malta, there are no problem, he personally are using BVI with bank account but he told me a lot of accountant are doing with UK︀ ltd without account and without problems...
this is a good sign that he not only advises but also uses it himself
have you asked about cfc?
How much were running costs for the previous year?
have you asked about cfc?
How much were running costs for the previous year?
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