Elective 15% final income tax (FITWI)
From year of assessment 2025, a company may elect a flat 15% final tax instead of 35% with shareholder refunds.
What changed and what to do
What changed
L.N. 188 of 2025 introduced the Final Income Tax Without Imputation. A company may elect a flat 15% final tax on chargeable income. The tax is final, with no credit, refund or set-off. The election locks in for 5 consecutive years, and an anti-arbitrage floor stops it undercutting the 35%-minus-refunds outcome.
Who it affects
- Maltese companies comparing tax routes
- Groups in scope of Pillar Two
- Shareholders who would otherwise claim refunds
What to do
Model the net position under 35% with refunds and under the 15% election, and take advice before electing, because of the 5-year lock-in.