Malta is one of the few countries that apply the full imputation system. By means of the full imputation system, the tax suffered and paid in Malta by the Malta company is directly attributed to the shareholder of the company.
Therefore, where the Malta company has suffered tax in Malta and makes a distribution of dividend in favour of the shareholder, the shareholder is not subject to any further tax in Malta upon the dividend received. Furthermore, where the dividend is distributed to a shareholder who is taxable in Malta at a rate of tax that is lower than the 35% of tax applicable to the company, that shareholder is entitled to claim a refund for the tax paid by the company in excess of the progressive rate applicable to the shareholder.
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