Transfer pricing in Malta: obligations are strengthened from January 1, 2024
The Transfer Pricing Rules have been revised by Legal Notice (LN) 9 of 2024 and published in the Government Gazette of Malta No. 21,182 of 19th January 2024. It amends the Transfer Pricing Rules related to the Income Tax Act (CAP. 123) in Malta.
The key points of the amendment are as follows:
- Effective Date: The amendment specifies that these rules shall apply for basis years commencing on or after January 1, 2024, concerning any arrangement entered into on or after that date. For arrangements entered into before January 1, 2024, these rules apply if the arrangements are materially altered on or after that date.
- Transition Period: For arrangements entered into before January 1, 2024, and not materially altered on or after that date, the rules will apply for basis years commencing on or after January 1, 2027.
Despite the lack of specific guidelines for preparing transfer pricing documentation, the application of LN 284 of 2022 is in force from January 1, 2024.
Having the documentation in place before the tax return date for the year of assessment (YA) 2025 should be sufficient.
Vanesa Ramos Ferrin - TransFair Pricing Solutions
Notes to editors
TFPS is an independent firm dedicated to providing tailor-made transfer pricing and valuation solutions to financial and corporate entities. TFPS team comprises transfer pricing and valuation experts who provide quality, expertise, commitment, independence, and fair solutions to its clients.
For further information about our organisation and services, please visit our website: www.tfps.lu
