Worldwide Tax Summaries--MALTA(1999-2000)(part1)(二)
颁布时间:2000-09-01
【From CFTInet, Beijing 09/01/2000】 CORPORATE TAXES
WITHHOLDING TAXES
Domestic corporations paying certain types of income are required to
deduct tax as follows.
RECIPIENT DIVIDENDS (1) INTEREST ROYALTIES
% % %
Resident corporations 35 35 (2) Nil
Resident individuals 35 25 (2) Nil
Nonresident corporations:
Nontreaty 35 Nil (3) Nil (3)
Nonresident individuals:
Nontreaty 35 Nil (3) Nil (3)
Nonresident corporations and individuals:
Treaty (4) Nil (3) Nil (3)
Australia 35
Austria 32.5
Belgium 35
Bulgaria 30
Canada 35
China, P.R 35
Cyprus 35
Czech Republic 35
Denmark 35
Finland 35
France 35
Germany 35
Hungary 35
India 35
Italy 35
Korea, Rep. of 35
Libya 15
Luxembourg 35
Netherlands 35
Norway 35
Pakistan 35
Poland 35
Romania 30
South Africa 35
Sweden 35
United Kingdom 35
Notes:
The numbers in parentheses refer to the notes below.
1. Malta makes no distinction between portfolio and substantial holdings.
No additional withholding tax is imposed on distributions other than the
tax charged on the company in respect of distributed profits. Under
Malta's full imputation system of taxation of dividends the corporate tax
is assimilated with the personal income tax of the shareholder in respect
of the dividend. In the shareholder's hands the dividend is charged to
tax gross, and the relevant amount of corporate tax is set off against
the shareholder's tax liability on income from all taxable sources.
2.Deduction is required only where the interest is debenture interest or
interest on any other loan advanced to a corporation for capital
purposes. Tax deductions are in effect prepayments of the submission of
returns. Any resulting overpayment is refunded.
3..Interest and royalty income derived by nonresidents is exempt from tax
in Malta as long as certain conditions are complied with (e.g., they are
not effectively connected to a permanent establishment of the recipient
situated in Malta).
4.Under its treaties Malta retains the right to tax dividends at a rate
not exceeding that paid by the company in question on the profits out of
which the dividends are distributed. This rate is currently 35%. In a
number of treaties the rate of deduction and of tax is reduced to 15% in
the case of companies enjoying certain tax incentives. See also Note 1
with regard to Malta's full-imputation system of taxation of dividends.
TAX ADMINISTRATION
Returns/A return of the income earned during the previous year must be
filed for every year of assessment. The year of assessment is a calendar
year, but the accounts during the basis year may, with Revenue
permission, be made up to a day prior to December 31. Companies are
assessed and pay tax in the currency in which their share capital is
denominated.
Payment of tax/Tax that is outstanding following an assessment is to be
paid income lump sum during the month following that in which the
assessment is raised. During the year, however, installments are to be
paid every four months on the basis of the last assessment received,
while on the submission of returns and tax computations any balance
outstanding between the tax as computed and as paid by installments is to
be paid in one lump sum by no later than the end of June in each year.
Tax on profits allocated to the Foreign Income Account becomes payable at
the earlier of the date of distribution of those profits and 18 months
after the end of the relative accounting period.
CORPORATION TAX CALCULATION
LOCAL FOREIGN INCOME
Lm Lm Lm Lm
Net profit before tax as
shown in the accounts for
fiscal year 1998 800,000 200,00
Add back amounts not allowable for tax purposes or that require adjustments:
Depreciation 200,000 10,000
Donations 5,000 ----
Increase in provision
for bad or doubtful
debts 5,000 ----
Structural alterations
of a capital nature 65,000 ----
Contributions to
unapproved pension
scheme 5,000 280,000 ---- 10,000
1,080,000 210,000
Less:
Initial allowances 125,000 ----
Wear-and-tear allowance 118,000 20,000
Balancing allowance 2,000 245,000 ---- 20,000
835,000 190,000
Add-Flat-rate foreign
tax credit (25% of 30000) ---- 7,500
Taxable income 835,000 197,500
Tax thereon at 35% 292,250 69,125
Less:
Double taxation treaty
relief (Note 1) ---- 12,000
Unilateral tax relief
(Note 2) ---- 10,000
Flat-rate foreign tax
credit (25%) (Note 3) ---- 7,500
Tax deducted at source
from dividend received
(Note 4) 35,000 (35,000) ---- (29,500)
Net tax payable (Note 5) 257,250 39,625
Notes:
1. Double taxation treaty relief is in respect of gross royalty income of
Lm120000 taxed at 10% in a foreign country.
2. Unilateral tax relief is in respect of income of Lm40000 taxed abroad
at 25%.
3. The flat-rate foreign tax credit is computed on income before payments
or other deductions of Lm30000 allocated to the Foreign Income Account,
in respect of which double taxation treaty relief and unilateral tax
relief are not claimed.
4. Tax has been deducted at source at 35% from dividends included gross
at Lm100000 in the net profits.
5. The net tax payable is Lm296,875, being the total of payable on local
income and the tax payable on foreign income.
6. Exchange rate of the Maltese lira at December 31, 1998: US$1=Lm0.3766.