Legally optimized holding solutions within the EU framework — sustainable tax outcomes for international businesses, built on genuine operational substance.
Holding structures that deliver — and that hold up
A Malta holding company can deliver participation exemption on dividends, refund mechanisms on trading subsidiaries, and full EU treaty access. We design and implement structures that work in practice, not just on paper.
Holding Design
Structure design based on your business, exit scenarios, DACH tax position, and long-term objectives.
Participation Exemption
Setup to qualify for Malta's participation exemption on qualifying dividends and capital gains.
Treaty Positioning
Alignment with Malta's double-tax treaty network — 75+ treaties including Germany, Austria, Switzerland.
Subsidiary Integration
Integration with existing operating companies and new trading entities.
Substance & Governance
Substance setup and ongoing governance to withstand AO/ATAD/BEPS scrutiny.
Exit & Succession Planning
Share structures designed with exit and succession scenarios in mind from day one.
Our holding process
Analysis of your current structure, business plan, and DACH tax situation.
Structure proposal with clear tax outcomes, substance requirements, and implementation roadmap.
Entity formation, transfers, agreements, and governance setup — coordinated with your German/Austrian advisors.
Ongoing tax compliance, governance, and structure reviews as your business evolves.
Why this matters for DACH entrepreneurs
A Malta holding is one of the most effective EU-compliant structures for DACH-region entrepreneurs — but only when it's designed around your actual business, not as a template. Participation exemption requires proper qualification. Treaty benefits require genuine substance. Exit planning requires the right share structure from the beginning. Done well, a Malta holding delivers significant, sustainable value; done poorly, it's an expensive compliance burden with no tax benefit.
Common Questions
What's the tax treatment of dividends received by a Malta holding?
Qualifying dividends from subsidiaries are exempt under Malta's participation exemption, provided specific ownership and holding-period conditions are met.
Can a Malta holding own my German operating company?
Yes — this is a common structure. It needs to be implemented with proper German AO substance considerations and coordinated with your German tax advisor.
How does the 6/7 refund work at the holding level?
The 6/7 refund applies to Malta trading companies, not the holding. A typical structure uses a Maltese trading subsidiary for active business and a Maltese holding to receive and retain profits.
Related Services
Let's design your Malta holding.
Book a free consultation. We'll review your current or planned structure and propose a Malta holding design that actually works.
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