Malta, on November 7, announced amendments to its notional interest deduction guidelines with respect to the attribution of deemed interest income.
A new paragraph entitled “Attribution of the Deemed Interest Income on Alternative Basis” is added as follows:
Where a shareholder is the only shareholder of a company that holds no more than 0.2% of the nominal value of the risk capital of such company and, in accordance with the Memorandum and Articles of Association, such holding is devoid of any rights to vote, to receive any dividends from the company and to particpate in the profits of the company, no deemed interest income shall be attributable to such shareholder, and the share of the deemed interest income that would have been attributable to such shareholder were it not for this paragraph (xii) shall be attributable to the other shareholders of the company in proportion to the nominal value of the risk capital of the company pertaining to each shareholder.
The guidelines further state that, for the new provision to apply, the taxpayer must make a written request to Malta’s Commissioner of Revenue.
Be the first to comment