Malta: Tax Treaties

Malta and Bulgaria have amended their double taxation treaty to align the Mutual Agreement Procedure with OECD standards, introducing a justification requirement that was conspicuously absent from the original text. While this change brings the treaty into conformity with international practice, the absence of mandatory arbitration provisions means taxpayers still lack a binding dispute resolution mechanism if competent authorities reach an impasse.

In recent years, Malta has become an attractive jurisdiction for high-net-worth individuals and families looking to establish Single Family Offices (SFOs) due to its robust regulatory environment and favourable tax regime.

On 20 September 2023, the General Court of the European Union ("GCEU"), in the case of Belgium v. Commission (Case T-131/16 RENV), in direct contrast to its initial decision in 2019, confirmed the