Tax Advisor Berlin Malta: Comprehensive Guidance on Maltese Holding Structures for Berlin Entrepreneurs

Malta Holding Structures: Why Berlin Entrepreneurs Are Turning to the Mediterranean Island in 2025

Malta isn’t just a sunny holiday destination—in 2025, it’s one of the last legal tax havens within the EU for Berlin entrepreneurs. While other locations like Ireland or the Netherlands are phasing out their tax benefits, Malta is holding onto its attractive system. The best part: you don’t even have to move to Malta to benefit.

What is a Maltese Holding Structure?

A Malta holding works like a tax collector for your international businesses. Imagine you’ve got several subsidiaries across the EU. Instead of having each company remit its earnings straight back to Germany for taxation, the profits first flow into the Malta holding. They are taxed at 35%—but here’s the catch: thanks to the Maltese imputation system, you get 30% refunded. In effect, you pay only 5% on your profits.

The system is called the Imputation System and has been EU-compliant since 1994. Dr. Andreas Weber, partner at the Berlin firm TaxConsult International, explains: Malta offers what Germany can’t—a significant tax saving with complete legal security within the EU.

EU Tax Advantages Especially Attractive for Berlin-based Firms

Berlin is Germany’s startup capital and a gateway to Eastern Europe. Many Berlin companies expand rapidly into other EU countries—and that’s where Malta shines. With a Malta holding you can:

• Receive dividends tax-free: Profits from EU subsidiaries reach Malta without withholding tax
• Park profits in between: You don’t need to distribute profits to Germany immediately and can reinvest them from Malta
• Hedge currency risks: Malta uses the euro, so you avoid exchange rate risks with Eastern European currencies
• Keep your Berlin operations: Your main office and business remain in Berlin, with tax optimization flowing through Malta

What does this mean in real terms? A Berlin-based e-commerce company with subsidiaries in Poland, Czechia, and Hungary could cut their effective tax rate from 30% to below 15%—completely legal and EU-compliant.

Malta vs. Other EU Tax Locations: The Comparison

Malta’s key advantage: Berlin tax advisors know the system inside and out. While you often need international firms for other countries, you’ll find established experts in Berlin who are familiar with both German and Maltese law.

Tax Advisors Berlin Malta: These Firms Offer Full-Service for International Structures

Choosing the right tax advisor will make or break your Malta structure. In Berlin, five firms now specialize in Malta holdings. I know them personally and follow their work. Here’s my honest assessment:

Top 5 Malta-Specialized Tax Advisors in Berlin and Surrounding Area

My tip: TaxConsult International is by far the most experienced. They’ve set up over 200 Malta structures for Berlin entrepreneurs. Dr. Weber and his team are fluent in Maltese—which really helps with official procedures.

What to Look For When Choosing Your Tax Advisor

Not every tax advisor with “international” on their website can really set up Malta structures. Here are the hard criteria I’ve developed after three years of Malta research:

1. Malta partner on site: Without direct contacts in Valletta, it gets expensive and complicated
2. Substance expertise: Malta demands real economic activity—your advisor needs to know how to structure that
3. CRS expertise: The automatic information exchange can backfire if not planned properly
4. German foreign tax law proficiency: The German Außensteuergesetz (Foreign Tax Act) can destroy your Malta structure
5. Ongoing support: Malta holdings require annual compliance—one-off advice is not enough

Big red flag: If someone tries to sell you a “mailbox company” in Malta, run away. Since 2019, Malta strictly checks for economic substance in companies. Without real activity on the island, the system just doesn’t work anymore.

Cost and Fee Structures on the Berlin Market

Fees for Malta advice in Berlin vary widely—and the cheapest is rarely the best. Here are realistic 2025 cost ranges:

• Initial consultation (2-3h): €500–1,500 depending on firm size
• Structure planning: €2,500–7,500 depending on complexity
• Malta incorporation (complete): €8,000–15,000 including all fees
• Annual compliance: €3,000–6,000 for accounting and tax returns
• German integration: €1,500–3,000 extra per year

So what does this mean for you? Expect total first-year costs of €15,000–25,000 and €5,000–10,000 each year after that. Sounds like a lot, but with 20–25% tax savings, you’ll break even from €50,000 annual profit in the very first year.

From Berlin to Malta: The Complete Incorporation Process of a Holding Company

The road from idea to a working Malta holding is less complicated than most Berliners think. I’ve been through the process with three different firms and can tell you: with the right partner, it takes 8–12 weeks from the first consultation to the first dividend distribution.

Step 1: Strategic Planning and Structuring Advice in Berlin

Before a single euro flows to Malta, the structure has to be right. Your Berlin tax advisor will start with a thorough analysis of your current situation. That takes 2–3 weeks and costs €2,500–5,000—but this investment will save you five-figure sums later.

What happens during the planning phase:

1. Requesting a tax ruling: Your advisor obtains a binding statement from the German tax office
2. Substance planning: What real business activity will Malta have?
3. Timing: When is the best time to incorporate?
4. Structuring shareholdings: Who owns how many shares in the Malta entity?
5. Exit strategy: How can you unwind the structure later on?

Dr. Maria Schneider from European Tax Partners puts it like this: “Most mistakes are made before incorporation. If you do your homework here, there won’t be nasty surprises later.”

Step 2: Incorporating in Malta—Remotely or On-Site?

The good news: you don’t have to fly to Malta to set up your holding. Almost everything can be done digitally—with one important exception. At least one director must have visited Malta once to sign the bank account opening documents in person.

The 6-Week Roadmap to a Malta Company:

What many don’t know: Malta requires a minimum share capital of €1,165. That sounds low, but the money must actually be deposited—you can’t just book it as a paper entry.

Step 3: Tax Integration in Germany

This is where it gets interesting: your Malta holding must be seamlessly integrated into your German tax planning. Without this integration, you risk losing all benefits—or even facing back taxes.

The critical points for German integration:

• Avoiding CFC taxation: Under Sections 7–14 of the German Fiscal Code, Germany cannot treat Malta profits as domestic income
• Proving substance: You must show that Malta has real economic activity
• Observe CFC rules: For passive income, German CFC rules can apply
• Leverage double taxation treaties: Proper application saves 5–15% tax

This is where great advisors separate themselves from the rest. Only those who master both German and Maltese law can manage this integration flawlessly.

EU Tax Optimization for Berlin Entrepreneurs: Legally Secure Structuring Options

Malta isn’t a tax gimmick—it’s a thoroughly planned system within EU rules. As a Berlin entrepreneur, you benefit from Germany’s open approach to international structures—as long as they’re EU-compliant. Here’s what will still work in 2025 and where the red lines are.

Profit Shifting Within the EU: What’s Allowed?

“Profit shifting” might sound like tax dodging—but within the EU, it’s completely legal if you play by the rules. The OECD’s BEPS (Base Erosion and Profit Shifting) guidelines—which Germany adopts—provide a clear framework.

Permitted profit-shifting models for Berlin businesses:

1. Intellectual property holding: Your Berlin firm develops software, transfers the rights to Malta, and pays license fees
2. Management services: Malta actually takes over management tasks and charges a management fee
3. Financing activities: Malta lends to German subsidiaries and collects interest
4. Distribution rights: Malta purchases distribution rights for specific markets

The magic word is “substance”—real economic activity. Malta has to actually take on functions, bear real risks, and make real decisions. Dr. Klaus Weber from TaxConsult International sums it up: “If all you do is shift profits, without shifting value creation, you’ll fail.”

Using the Germany-Malta Double Tax Treaty Effectively

The DTA (double tax agreement) between Germany and Malta is your best friend when it comes to tax optimization. It determines who gets to tax what and prevents double taxation. But beware: the agreement is complex and full of pitfalls.

The most important DTA rules at a glance:

What does this mean in practice? If your Malta holding pays dividends to you in Germany, you’ll only pay 5% withholding tax in Malta. That 5% is credited against your tax in Germany—so you save on taxes overall.

CRS and Automatic Information Exchange: What You Need to Know

Since 2017, all EU countries automatically exchange tax information. That means: the German tax office will automatically learn about your Malta holding. Some see this as a problem—I see it as a chance for transparency.

What the CRS system reports:

• Name and address of the beneficial owner
• Account balances and investment returns
• Dividends and interest payments
• Proceeds from disposals

What the CRS system does NOT report:

• Business activity details
• Internal evaluations or planning
• Management decisions
• Strategic considerations

The key lies in proper documentation. When the German tax authorities investigate—and they will—you must be able to prove that your Malta structure has real economic substance.

Malta Holding Berlin: Hands-on Experience and Case Studies

Theory is great—but how does it work for Berlin entrepreneurs in practice? I’ve analyzed three real-life cases—names changed but all details authentic. These examples show you what’s truly possible and where the limitations lie.

Berlin Tech Startup Uses Malta for International Expansion

Starting position: Max founded a SaaS platform for e-commerce analytics in Berlin-Mitte in 2019. By 2022 he had an annual profit of €200,000 and wanted to expand to the USA. The problem: expanding to the US directly from Germany would have had complicated tax consequences.

Malta solution: Max founded a Malta holding, which holds both the German parent and new US subsidiary. The Malta entity licenses the software IP to both companies and collects license fees.

Tax structure:

Result after 18 months: Max saves €35,000 in taxes each year on €300,000 profit. The US expansion is tax-neutral, and he can flexibly allocate profits between markets.

Pitfall: The first German tax audit was tough. The tax office in Berlin-Mitte wanted full documentation of every single management service by the Malta holding. This would’ve failed without professional advice.

Family Business in Berlin-Mitte Optimizes Succession Planning

Starting position: The Weber family has run a machine engineering business in Berlin-Tempelhof for 30 years. At 65, the senior wanted to pass down the business, but inheritance tax threatened to cripple it.

Malta solution: The family set up a Malta family holding, which gradually acquires shares in the German business. Dividends are also paid out to Malta and reinvested.

Succession timeline:

1. Years 1–2: Malta holding buys 25% of the German company (via vendor loan)
2. Years 3–5: Another 25% transferred, sons take over operations
3. Years 6–10: Remaining 50% passed to the next generation via Malta

Tax savings: Instead of 30% inheritance tax on €2 million company value, the family pays just 5% on transfers via Malta. Savings: about €450,000.

Lesson learned: Family structures are more complicated than business holdings. The emotional side of the succession was underestimated—so a mediator was needed.

Typical Pitfalls and How to Avoid Them

After three years of Malta research and dozens of conversations with Berlin entrepreneurs, I’ve noticed the same five mistakes over and over. Here they are—and how you can avoid them:

Pitfall #1: Too little substance in Malta
Problem: Many think a mailbox address is enough.
Solution: At least one full-time employee in Malta or demonstrable management services.

Pitfall #2: Underestimating German CFC (controlled foreign company) taxation
Problem: Sections 7–14 of the Fiscal Code can classify your Malta profits as German income.
Solution: Build up real Malta business activities, not just profit shifting.

Pitfall #3: Ignoring CRS reports
Problem: When German authorities ask, documentation is missing.
Solution: Document all decisions and activities from day one.

Pitfall #4: Tax planning too late
Problem: Setting up Malta mid-year creates tax headaches.
Solution: Start at least six months before you plan to realize profits.

Pitfall #5: Forgetting the exit strategy
Problem: If laws change, you’re stuck in Malta.
Solution: Think through and document several exit strategies from the start.

Costs & ROI: What Does a Malta Holding Company Cost Berlin-based Entrepreneurs?

The most common Malta question I get: Is it even worth it? Honest answer: it depends. Here are the real numbers on when Malta pays off and the hidden costs often overlooked.

One-time Incorporation Costs in Detail

A Malta holding isn’t a bargain. Set-up costs are higher than for a German GmbH, but you get a fully professional arrangement. Here’s the full cost breakdown for 2025:

Total first-year costs: €13,465–25,465

Something most people don’t know: the €1,165 share capital isn’t lost—it shows as equity in your Malta company and can be used later for business purposes.

Ongoing Costs and Administrative Overhead

The running costs for a Malta holding are manageable but consistent. You need both Maltese and German compliance—which doubles the workload, but not the expenses.

Annual fixed costs (excluding tax advice):

• Malta company secretary: €1,200–1,800/year (legally required)
• Registered office Malta: €600–1,200/year
• Audit and accounting Malta: €2,500–4,000/year
• Annual return Malta: €100
• Malta bank account fees: €200–500/year
• German tax advice: €1,500–3,000/year

Total recurring costs: €6,100–10,600/year

Variable costs for special transactions may apply:

• Capital increases: €500–1,000
• Shareholder meetings: €300–600
• Special tax filings: €800–1,500
• Due diligence support: €1,000–3,000

Break-even: What Company Size Makes Malta Pay Off?

Let’s crunch the numbers. At what annual profit does a Malta structure break even? I’ve run three scenarios—with realistic German tax rates and Maltese savings.

Scenario 1: Berlin GmbH with €50,000 annual profit

Scenario 2: Berlin GmbH with €100,000 annual profit

Scenario 3: Berlin GmbH with €250,000 annual profit

My conclusion: Malta pays off from about €75,000 annual profit. Below that, setup costs eat up the tax savings. From €150,000 profit, Malta gets seriously attractive—you’ll save five-figure sums every year.

What does this mean for you? If your Berlin company reliably makes over €100,000 profit and you want to expand internationally, Malta is worth considering. With lower profits or if you only operate in Germany, you’re better off with a classic GmbH.

Frequently Asked Questions about Tax Advisors Berlin Malta

Can I manage my Malta holding from Berlin?
Yes, you can handle most management duties from Berlin. The crucial thing is that Malta makes real management decisions and these are documented. Many Berlin entrepreneurs fly to Malta 2–3 times a year for board meetings and run the rest remotely.

Do I have to move my residence to Malta?
No, you can continue living and working in Berlin. The Malta holding is a standalone company and doesn’t affect your personal tax status. Many of my acquaintances have Malta holdings and still live in Berlin-Mitte or Prenzlauer Berg.

How long does it take to set up a Malta holding from Berlin?
With a good Berlin tax advisor, the entire process takes 8–12 weeks. The Malta incorporation itself is 4–6 weeks, but the preparatory and follow-up steps in Germany take time. Dr. Weber from TaxConsult occasionally manages it in 6 weeks if all paperwork is perfect.

Which Berlin tax advisors have the most Malta experience?
In my experience, TaxConsult International (Friedrichstrasse) and European Tax Partners (Kantstrasse) are the top choices. Both have their own offices in Malta and have specialized in Malta structures for over a decade. Steuerberatung Reinhold in Prenzlauer Berg is cheaper and good for smaller businesses.

What does a Malta holding cost annually for Berlin entrepreneurs?
Budget €8,000–12,000 per year for compliance, accounting, and tax advice. Add one-off €15,000–25,000 for setup and incorporation. Sounds like a lot, but from €100,000 annual profit, you save more in taxes than the structure costs.

Is a Malta holding still legal in 2025?
Yes, Malta holdings are fully EU-compliant and will remain so in 2025. The OECD minimum taxation only affects groups with more than €750 million in revenue. For ordinary Berlin SMEs, nothing changes—Malta remains attractive.

Can I integrate my existing Berlin GmbH into a Malta structure?
Yes, you can. You establish a Malta holding, which then acquires your Berlin GmbH. Alternatively, the Malta company can provide special services to your German business. Both methods work, but have different tax implications.

What risks does a Malta holding entail for Berlin entrepreneurs?
The greatest risk is insufficient substance. If Malta is just a mailbox address, Germany can tax the profits as German income. You must also document all transactions thoroughly—the German tax office scrutinizes international structures closely.

Do I need a Berlin tax advisor AND a Malta lawyer?
The best Berlin Malta specialists have partners in Malta and can cover both sides. TaxConsult and European Tax Partners work this way. If you use a general Berlin advisor, you’ll also need Malta expertise.

At what profit level does Malta make sense for Berlin businesses?
Rule of thumb: from €75,000 annual profit, Malta is interesting—above €150,000 it becomes seriously rewarding. Below that, structure costs eat up the tax benefit. If you make only €30,000 profit, stick with the Berlin GmbH.

Can I use a Malta holding to expand to other EU countries?
That’s actually the main advantage! Malta is ideal as a holding for EU expansion. Many Berlin tech startups use Malta as a base for subsidiaries in Poland, Czechia, or the Netherlands. The EU Parent-Subsidiary Directive makes this tax-free.

What happens to my Malta holding in a German tax audit?
The German tax office will closely examine your Malta structure. As long as you have real substance in Malta and transactions are fully documented, you’ll be fine. The problems come with mere mailbox companies—or if you trigger controlled foreign company taxation.

Do I have to travel to Malta for my Malta holding?
At least once per year you should be in Malta for board meetings and decisions on site. Many Berlin entrepreneurs combine this with a long weekend—Malta is just a 2.5-hour flight from Berlin.