Malta Holding Company: What You Must Show Before a Bank Says Yes

Incorporation takes two to four weeks. Banking takes longer, and that is where structures fail. What substance means operationally — and why the 6/7ths refund depends on it.

Summary Incorporating in Malta takes two to four weeks . Getting a bank to accept the company takes longer, and that is where most structures fail. The refunds everyone quotes — 6/7ths on trading profits, an effective rate near 5% — are only defensible on a company with real substance. ATAD, CFC and transfer pricing rules apply. Substance is not an address. It is where decisions are taken, who takes them, and whether you can evidence both a year later. The gap between registered and bankable A Maltese company is straightforward to form. A complete file reaches an operating company in two to four weeks, subject to KYC and banking. Professional fees are quoted on request; official registry charges are billed separately. Banking is the qualifier doing all the work in that sentence. A compliance officer is not assessing your incorporation certificate. They are assessing whether the entity does something, somewhere, that they can explain to their own regulator. What the tax system actually offers Malta charges 35% on company profits under a full imputation system. On distribution, qualifying shareholders claim a refund. Profit type Refund Effective outcome Trading profits 6/7ths ~5% Passive interest and royalties 5/7ths Higher Where treaty relief is claimed 2/3rds Higher Alongside it: a participation exemption that can take qualifying dividends and capital gains to 0%, no withholding tax on outbound dividends, interest or royalties, and 70+ double tax treaties plus EU directive access. Group consolidation can deliver the ~5% outcome at source rather than through the refund cycle, where the structure qualifies. None of that is exotic. It is general law rather than a special regime, which is exactly why it survives scrutiny that special regimes do not. What a bank and a tax authority both look for The same things, for different reasons. Directors who decide. Resident directors who can explain the business, not signatories who forward documents. Decisions taken in Malta. Board meetings…