By means of LN 411 of 2018 Malta implements the ATAD which contains four measures in relation to interest limitation, exit taxation, GAAR and controlled foreign company rules.
These rules apply to all companies as well as other entities that are subject to tax in Malta in the same manner as companies, including entities that are not resident in Malta but that have a permanent establishment in Malta. The new regulations shall come into force on 1 January 2019, with the exception of the regulations relating to exit taxation, which shall come into force on 1 January 2020.
