The Malta company first pays the full 35% corporate tax in Malta. Once that's done, the parent company applies for a tax rebate of up to 6/7 (six sevenths). 35*(6/7)=30. As long as the shareholder lives up to the requirement of being non-resident and non-domiciled, the request is approved.
If you are a foreigner living in Malta, you only︀ fulfill one of those two criteria: you are non-domiciled, but you are resident. So residents︁ set up companies which qualify as tax resident through incorporation (such as UK), or simply︂ rely lack of enforcement from IRD and use non-resident companies (such as BVI).
So if︃ the Malta company paid 70,000 EUR in corporate tax against 200,000 EUR profits, the parent︄ company would get 60,000 EUR back. This makes your net tax rate 5%.
In many,︅ but not all, cases the tax rebate is not in scope for corporate income tax︆ for the holding company. I'm not familiar enough with Mexico to comment on that specifically.︇
To use the money for yourself, people (expats in Malta) often pay themselves a tiny︈ salary of around 9,000 EUR from the Malta company which is not subject to tax.︉ The rest of the money, they take out from the parent company one way or︊ another. There are different, creative ways to do that as a non-domiciled resident.
Technically, if︋ you are a non-resident of Malta, you don't even need a holding company since you,︌ as a natural person, satisfy the criteria. But then you have a local tax burden︍ to worry about. The structure works best if you are resident in Malta, or can︎ pay yourself money from the holding company in a tax efficient way.
If you are a foreigner living in Malta, you only︀ fulfill one of those two criteria: you are non-domiciled, but you are resident. So residents︁ set up companies which qualify as tax resident through incorporation (such as UK), or simply︂ rely lack of enforcement from IRD and use non-resident companies (such as BVI).
So if︃ the Malta company paid 70,000 EUR in corporate tax against 200,000 EUR profits, the parent︄ company would get 60,000 EUR back. This makes your net tax rate 5%.
In many,︅ but not all, cases the tax rebate is not in scope for corporate income tax︆ for the holding company. I'm not familiar enough with Mexico to comment on that specifically.︇
To use the money for yourself, people (expats in Malta) often pay themselves a tiny︈ salary of around 9,000 EUR from the Malta company which is not subject to tax.︉ The rest of the money, they take out from the parent company one way or︊ another. There are different, creative ways to do that as a non-domiciled resident.
Technically, if︋ you are a non-resident of Malta, you don't even need a holding company since you,︌ as a natural person, satisfy the criteria. But then you have a local tax burden︍ to worry about. The structure works best if you are resident in Malta, or can︎ pay yourself money from the holding company in a tax efficient way.