and the smart corporate tax system in Malta with Full Imputation and NID (notional interest deduction)



Corporate income tax (CIT) rate cuts have continued in 2019, but these rate reductions have been
less significant than the ones introduced in 2018… this is one of the tax-reducing because you can set up a business with much fewer borders friction #maltaway

The average tax rate of all European countries covered has declined from 22.8 percent in 2017 to 22.3 percent in 2019.

Changes in Top Combined Corporate Income Tax Rates

Country           2017  2018  2019

Belgium (BE) 34.0% 29.6% 29.6%
France (FR) 44.4% 34.4% 34.4%
Greece (GR) 29.0% 29.0% 28.0%
Latvia (LV) 15.0% 20.0% 20.0%
Lux (LU) 27.1% 26.0% 25.0%
Norway (NO) 24.0% 23.0% 22.0%
Portugal (PT) 29.5% 31.5% 31.5%
Sweden (SE) 22.0% 22.0% 21.4%
Turkey (TR) 20.0% 22.0% 22.0%


Al fine di individuare un corretto modo per applicare la corporate tax, suggerisco di dare un’occhiata al sistema fiscale maltese riferito alle società per un motivo principale che ho riassunto in pochissime parole:
Il sistema chiamato FULL IMPUTATION, in cui i dividendi distribuiti su profitti tassati, incorporano un credito di imposta per parte dell’imposta pagata dalla società, attuando di fatto un modello quasi simile alle società “passthrough” statunitensi anziché al modello delle società C – Vedi immagine no borders international advisory partners il tuo hub per trasferire nelle migliori giurisdizioni Business, Assets, Cittadini
lowering the real Corporate Tax to 5% from the nominal one of 35%, the smart and fair solutions of Full Imputation System, where dividends distributed out of taxed profits, are carrying an imputation credit of the tax paid by the company, having de-facto a quasi-similar model to the US passthrough firms instead of C corporations model no borders international advisory partners your hub for a re-location for business Assets and people

Europe and global bad practices and regulation incentivizing CORPORATE DEBT instead of EQUITY, MALTA has instead a fair NID policy

IN MALTA is different having a model to avoid the bias of “advantageous debt financing model”. Malta has introduced for the fiscal year 2018 a NID model or notional interest deduction, giving a tax neutrality to the equity financing and debt financing
NID is calculated as the risk-free rate referred to the current yield to maturity on Malta government stocks with a remaining term of approximately 20 years, plus a 5% premium

Thin-Cap Rules in Europe

High-tax countries create an incentive for companies to finance investments with debt because interest payments are tax-deductible, which is usually not the case for equity costs.
This encourages global businesses to lend money internally from entities in low-tax countries to entities in high-tax countries. Tax savings in high-tax countries can exceed the increased tax paid in low-tax countries, decreasing worldwide tax liability.
To discourage such international debt shifting, many countries have implemented so-called thin-capitalization rules (thin-cap rules), which limit the amount of interest a multinational business can deduct for tax purposes. The two most common types used in practice are “safe harbor rules” and “earnings stripping rules.” Safe harbor rules restrict the amount of debt for which interest is tax-deductible by defining a debt-to-equity ratio. Interest paid on debt exceeding this set ratio is not tax-deductible. Earnings stripping rules limit the tax-deductible share of debt interest to pretax earnings.
thin-cap rules, thin-capitalization rules, debt-to-equity ratio, safe-harbor rules, debt shifting
More than half of the European countries covered have interest-to-pretax-earning limits in place. Most commonly, the limit is set at 30 percent of EBITDA (Earnings Before Interest, Taxes, Depreciation and Amortization). For instance, a parent company takes a $100 loan from its subsidiary requiring interest payments of $5. EBITDA are $10, so only $3 (30 percent of $10) of the $5 in interest paid are tax-deductible.
Some of the countries have debt-to-equity ratios in place. For instance, Turkey’s debt-to-equity ratio is 3:1. Let’s say a Turkish business takes a $100 loan from its foreign subsidiary. Its current equity amounts to $10, resulting in a debt-to-equity ratio of 10:1. The annual interest on the loan is 5 percent, or $5. Because the business’ debt-to-equity ratio is twice the limit, only half of the interest, or $2.5 of the $5, is tax-deductible.

Because when the #asimmetry #transparency #conflictofinterest #novaluedelivered #notransparency are too high, the market shifts away accordingly #maltaway

Your assets governance (people & capital) independent international advisory & education partners the choice for the best assets allocation and of the best jurisdictions for you your business your assets #investments #wealthmanagement #monetarypolicy #investors #wealthprotection