On 17 December 2019 Legal Notice 342 introduced regulations implementing the European Union Directive on the mandatory disclosure and exchange of cross-border tax arrangements were published (commonly referred to as DAC6). The regulations had to come into force as from 1 July 2020, however their enactment was postponed due to pandemic. The new effective date […]

On 1 October 2020, Malta and Russia signed a Protocol amending the Convention for the Avoidance of Double Taxation and the prevention of Fiscal Evasion between the two countries. This new Protocol includes amendments to Article 10 of the Convention concerning dividends payments, Article 11 concerning interest payments as well as Article 24 being the Non-Discrimination […]

The British Virgin Islands government has officially announced its commitment to the implementation of public registers of beneficial ownership in the territory, despite “reservations”. Premier Andrew Fahie said: “Your government commits to working in collaboration with Her Majesty’s Government towards a publicly accessible register of beneficial ownership for companies, in line with international standards and […]

On 8 September 2020, the Republic of Cyprus and the Russian Federation signed the Protocol to amend the double tax treaty between the two countries. The amendments to the Treaty should be effective as of 1 January 2021 (provided the Protocol is ratified by both parties by the end of 2020). We hereby list the most […]

As empowered by Article 98(2) of the Income Tax Act, the Commissioner For Revenue has, on 31 August 2020, published a set of guidelines (the Guidelines) concerning the scope, interpretation and application of the Anti-Tax Avoidance Directives (ATAD) Implementation Regulations (S.L.123.187.) with particular reference to the Interest Deduction Limitation rules, Exit Taxation, Controlled Foreign Company […]

Russia has announced it is unilaterally cancelling its double taxation agreement (DTA) with Cyprus, following the failure of negotiations to amend the treaty in line with Moscow’s new anti-offshoring business tax regime. In April 2020, President Vladimir Putin announced a new 15 per cent tax on dividend payments from Russian businesses to parent companies in […]

Introduction In a landmark ruling, the General Court of the European Union has annulled the 2016 adoption of a decision taken by the Commission regarding Irish tax rulings granted in favour of Apple. The Court concluded that the Commission failed to prove, to the requisite legal standard, that the tax rulings granted by the Irish […]

The Honourable Alex Muscat, M.P., Parliamentary Secretary for Citizenship and Communities on the 30th June 2020 presented a bill introducing changes to the Maltese Citizenship Act and proposing a new residence program leading to Maltese citizenship. The new program, if approved by the Parliament, will completely replace Malta Individual Investor Programme, which as it was […]

In line with the publication and coming into force of COUNCIL DIRECTIVE (EU) 2020/876 of 24 June 2020 amending Directive 2011/16/EU to address the urgent need to defer certain time limits for the filing and exchange of information in the field of taxation because of the COVID-19 pandemic, the Commissioner for Revenue will be deferring […]

The international community continues to make ‘tremendous progress’ in the fight against offshore tax evasion, according to the Organisation for Economic Co-operation and Development (OECD). The Paris-based regulator said this week that implementation of transparency standards by the organisation’s Global Forum on Transparency and Exchange of Information for Tax Purposes has “moved many countries ever closer to […]

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