Tax Structuring
Across the Mediterranean
Episode 02 of the Mediterranean Alliance focused on the tax and business implications of relocating from Germany, with Malta and Gibraltar considered as potential international locations.
Alfons Schwarte, Adrian Kreter and Prof. Dr. Adrian Cloer discussed different approaches to international corporate and wealth structures, the importance of substance and tax residency, as well as practical topics such as banking, holding structures, double-tax treaties and the individual's actual centre of vital interests.
The discussion made one point particularly clear: there is no single ideal jurisdiction. Malta and Gibraltar can fulfil different roles within an international structure. The right solution depends on the business model, the entrepreneur's personal circumstances and careful planning before relocation.
Watch the Webinar.
Watch the full recording and revisit the key insights, discussions and answers to the questions raised by participants during the session.
- Held
- Fri · 28 August 2026
- Language
- German
- Format
- Live webinar online
- Recording
- Available below
Watch the full session
Revisit the presentations, the discussion and the live Q&A in full.
Three Jurisdictions — One Bigger Picture.
- International holding structures
- Specific residence and tax regimes for qualifying individuals
- Corporate structures that may be possible without a local director
- Financial services, online gaming and digital assets
- Trusts and more sophisticated international wealth structures
- Malta's full-imputation system and possible refund mechanisms
- Holding structures
- Substance and genuine business activity
- An English-speaking and internationally oriented business environment
- A broader double-tax treaty network compared with Gibraltar
- Tax implications of relocating from Germany
- Exit taxation
- Withholding-tax considerations
- The actual centre of vital interests as a factor in determining tax residence
- The interaction between the shareholder's tax position and an overseas company
Four Key Takeaways.
Careful Planning
Relocating from Germany and restructuring an internationally active business should not be viewed in isolation. Residence, company structure, business activity and the individual's personal tax position need to be assessed together.
Substance Matters
Malta and Gibraltar can both be attractive international business locations, but they have different requirements in relation to management, residence, operational activity and economic substance.
Banking Is Part of the Structure
Business accounts, private banking and wealth management are important elements of international structures. Banking requirements and risk profiles should therefore be considered at an early stage.
There Is No One-Size-Fits-All Solution
Malta, Gibraltar and Germany each fulfil different roles. The most suitable structure depends on the entrepreneur, the business model, personal tax residency and long-term objectives.
The Experts.
Adrian Kreter
Portfolio Investor · Business Angel · Board of Directors
Turicum Private Bank · Arringo Group · ArriTech
Prof. Dr. Adrian Cloer
Tax Advisor · Specialist Tax Lawyer · Professor of Tax Law
Forvis Mazars · EBS University
Alfons Schwarte Host
Managing Director · Euro Tax Consulting
Host of the Mediterranean Alliance
Discussion Highlights.
Gibraltar as a Holding Jurisdiction
The discussion showed that Gibraltar may be particularly relevant as an international holding or complementary jurisdiction rather than necessarily serving as the main location of an operating business.
Banking & Financial Services
The panel discussed business accounts, private banking, wealth management and the role of specialised financial institutions in more complex international corporate and private wealth structures.
Companies, Compliance & Security
Further topics included company formation, local requirements, annual accounts, audit obligations and the practical differences between Malta and Gibraltar.
Your Questions Answered
During the live Q&A, the experts addressed questions relating to health insurance, residence requirements, German withholding-tax refunds, banking and practical experiences with local service providers.
The Mediterranean Alliance Continues.
More jurisdictions. More perspectives. More opportunities. Explore further episodes of the Mediterranean Alliance and gain practical insights into international business structures, relocation and cross-border planning.
