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81 Zero-Employee Companies In Malta Each Topped €10 Million In Taxable Income

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Eighty-one companies with no employees each declared taxable income of more than €10 million in Malta, Finance Minister Clyde Caruana said in parliamentary replies.

Caruana gave the figures in response to questions from Opposition MP Adrian Delia about multinational corporate structures and Malta's tax system. The minister said the analysis had identified 81 companies that reported no staff yet declared taxable income in Malta above €10 million each. Employee numbers alone, he added, do not establish a company's functions, activities or tax position.

In separate replies, Caruana set out Malta's participation in assessments by the European Union's Code of Conduct on Business Taxation and in OECD peer reviews covering international transparency and anti-tax avoidance standards. He described these as part of Malta's obligations as an EU member and as a participant in international organisations.

Asked what stops the use of letterbox companies or entities without genuine economic activity, the minister pointed to beneficial ownership requirements, reporting obligations and compliance rules arising from EU directives and OECD standards. He said the government keeps monitoring international developments and will update legislation where necessary, while seeking to balance fiscal integrity with economic competitiveness.

Caruana also confirmed that the Finance Ministry had not carried out any study of the reputational risks to Malta as a financial centre arising from the tax arrangements available to multinational companies.

In a separate disclosure, the minister said tax liabilities declared in Malta by local entities belonging to major US multinational groups rose from €24.7 million in 2020 to €118 million in 2024. The 2024 figure was almost double the previous year's total and nearly five times the amount recorded in 2020.

Those figures relate to Maltese entities identified through DAC4 notifications, the EU's country-by-country reporting framework for large multinational groups. Caruana said the liabilities were due under Maltese fiscal law and reflected the activities and economic substance of the entities operating in Malta.

For the purposes of the question, American multinational companies were defined as groups whose ultimate parent is resident in the United States and which fall within DAC4 reporting requirements. Those requirements apply to multinational groups with annual consolidated revenues of at least €750 million.

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