EU's notional 35% rate refunds down to 5% effective for shareholders, full imputation system, 70+ treaties.
When Malta is the right call, and when it is not.
The MGA is a Tier 1 gaming regulator covering B2C and B2B licences for casino, sportsbook and lottery, recognised across most regulated EU markets. English language admin and EU passporting support multi market rollouts.
Malta's Refundable Imputation system lets non resident shareholders claim a 6/7 refund on the 35% CIT, taking the effective rate to 5%. Requires a holding plus trading structure and onshore substance to satisfy MFSA and ATAD.
MFSA was an early VASP (virtual asset service provider) supervisor and is now MiCA (EU crypto framework) national competent authority. English contracts, common law influenced company law, and full participation exemption on qualifying dividends round out the structure.
The 6/7 refund creates PFIC and GILTI exposure for US shareholders, and the system is under continuous EU scrutiny. If your cap table includes US persons:
Malta was on the FATF grey list until June 2022 and the refund regime remains under EU state aid scrutiny. For tier one institutional optics:
Working data for Malta. Cite check each figure before use.
Bundle for Malta, one invoice.
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Each rate, threshold, and deadline below is cited from an authoritative source.
Information is provided for general guidance and reflects tax year 2025 unless noted. Specific situations require advice from a local practitioner. Always confirm against the cited tax authority and registrar before relying on a figure.