Ensuring POEM compliance, governance standards, and MFSA/MGA licensing — building genuine operational substance that holds up to scrutiny.
Operational substance that withstands tax authority review
Malta's tax advantages depend on genuine substance — real management, real decisions, real operations in Malta. We structure and document this correctly, and handle the licensing processes where your activity requires MFSA, MGA, or sector-specific authorization.
POEM & Management Substance
Place of Effective Management setup — board composition, meeting schedules, local directors, decision documentation.
Office & Staff Substance
Physical office, local employees, and operational activity meeting BEPS and German AO substance tests.
Corporate Governance
Articles, board procedures, shareholder agreements, and compliance manuals meeting Maltese and EU standards.
MFSA Licensing
Financial services licensing — investment services, fund management, insurance, and credit institutions.
MGA Licensing
Remote gaming licensing across all MGA license classes, including technical audits and compliance documentation.
Sector-Specific Authorization
Sector-specific permits and registrations depending on your business activity.
Our substance process
Review of your current or planned structure against POEM, BEPS, and German CFC rules.
Concrete list of what's missing — directors, office, staff, documentation, processes.
Execution of all substance elements — recruitment support, office setup, governance documentation, licensing application.
Board calendar, minute-taking, annual reviews, and licensing renewal management.
Why this matters for DACH entrepreneurs
Germany's Außensteuergesetz and Austria's equivalent substance rules mean that a Malta company without real operations is treated as a domestic entity for tax purposes — defeating the entire structure. MFSA and MGA licensing adds another layer: fail the substance test and the license can be revoked, shutting down regulated activity entirely. Getting substance and licensing right is what separates a working structure from an expensive mistake.
Common Questions
What's the minimum substance required for a Malta company?
There's no single threshold, but realistic expectations are: at least one Malta-resident director, physical office (not a virtual address), locally taken board decisions with documented minutes, and operational activity matching the company's stated business.
How long does MFSA licensing take?
Depends on license class — typically 6–12 months for investment services or fund management, longer for credit institutions. MGA licensing is generally 3–6 months.
Does my German tax advisor accept Malta substance if it's properly structured?
Yes, if the substance is genuine and documented. We provide the evidence pack your Steuerberater and the Finanzamt need to recognize the Malta structure.
Related Services
Let's build substance that holds up.
Book a free consultation. We'll review your current substance position and outline what needs to change.
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