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In today’s dynamic global economy, transfer pricing has become a critical tax concern for companies involved in cross-border operations. This term refers to the pricing arrangements among associated enterprises within a group, covering transactions involving the transfer of intellectual property, tangible goods, services, loans, or other financial transactions.

In light of the formal introduction of the Transfer Pricing Rules in Malta, which are effective from 1 January 2024, transactions between companies in the same group merit further consideration. These regulations are applicable to intra-group cross-border transactions taking place on or after 1st January 2024 or cross-border transactions that occurred before 1 January 2024 which have undergone material alterations following this date.

While the Arm’s Length Principle has always been implicit in our Income Tax Legislation, Malta has not previously imposed any formal obligations on taxpayers to prepare and submit Transfer Pricing documentation to local Tax Authorities.

What concerns are currently most pressing? 

Legal Notice 284 of 2022 outlines the criteria for entities that may potentially fall within scope of these rules.

The local tax authorities have issued preliminary guidelines for implementing Legal Notice 284 and together with the legislation, it provides clear exemptions and opt-outs for preparing and submitting transfer pricing documentation.

What exactly is a transfer pricing health check?

A Transfer Pricing Health Check essentially necessitates a comprehensive    understanding of the group companies and their transactions. This understanding would allow us to assess compliance with the relevant rules and regulations and to determine whether the entities and their transactions fall within scope of the new Transfer Pricing Rules.

Ensuring compliance with transfer pricing regulations through a thorough health check is vital for safeguarding your business against potential risks and ensuring the smooth operation in the increasingly complex global tax landscape.

How can we help?

Our Transfer Pricing team, specifically trained to handle benchmarking analyses for intra-group transactions may offer support to a Maltese target entity by analysing group transactions from a Transfer Pricing perspective and assist with the preparation and submission of any relevant documentation.

Matthew Zampa


Luke Aquilina

Tax & Transfer Pricing Senior Team Leader

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