Full Imputation System

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 company has suffered tax in Malta and makes a distribution of dividend, the shareholder in receipt of the dividend is not subject to any further tax in Malta upon that dividend. Furthermore, where the dividend is distributed to a shareholder who is taxable in Malta at a rate of tax that is lower than 35%, that shareholder is entitled to claim a refund of the tax paid by the company in excess of the rate applicable to that shareholder.