Tax Advisor Bremen Malta: Your Guide to Maltese Tax Models for Bremen-Based Businesses

Malta as a Tax Jurisdiction: What Bremen Entrepreneurs Need to Know

Malta isn’t a tax haven in the traditional sense—it’s better. Real tax havens often end up on gray lists or face trouble with the German tax authorities, but Malta is a full EU member with all the associated rights and obligations. That means: you can benefit from all EU directives with no reason for the Bremen tax office to be suspicious.

The Maltese Full Imputation System: Why 35% Actually Means 5%

The advantage lies in Malta’s Full Imputation System. Officially, you pay 35% corporate tax on profits from your Malta company. But—and here’s the interesting bit—if you distribute dividends to your German holding, you get 6/7 of the tax you paid refunded. So your 35% is effectively reduced to 5%. For example: your Malta Ltd. makes €100,000 profit. You pay €35,000 corporate tax. Distribute €65,000 as a dividend to your Bremen holding and you’ll receive a €30,000 tax refund from Malta. Effective tax: only €5,000 instead of €35,000.

Substance Requirements: What Malta Expects from You

Malta doesn’t hand out tax benefits for free. You need genuine economic substance on the ground. In practice, this means:

• At least one qualified director residing in Malta
• Office premises (a mailbox won’t suffice)
• Local bookkeeping and financial statements
• At least two board meetings per year in Malta
• Proof of real business activities

The good news: As a Bremen entrepreneur, you can fulfill these requirements through specialized service providers—there’s no need to commute to Valletta every day.

The Best Maltese Tax Models for Companies from Bremen

Not every Maltese tax model is a fit for every Bremen business. The right structure depends on your business activity, company size, and objectives.

Trading Company: For Bremen-Based Trading Businesses

If you run a trading company in Bremen, the Malta Trading Company is often the go-to choice. This structure is especially suitable for:

• Import/export business between Bremen and third countries
• Internationally oriented e-commerce
• Licensing and intellectual property deals
• Commodities trading via Bremen’s port

The key: you often pay just 5% tax on passive income (dividends, interest, royalties). For active trading profits, the full imputation system applies with an effective 5% tax burden.

Holding Company: The Malta Bridge for Your Bremen Group

Do you own multiple companies or plan acquisitions? A Maltese holding can optimize your Bremen-based structures for tax. The participating exemption ensures that dividends from subsidiaries can be received tax-free.

Intellectual Property Company: For Bremen’s Innovators

Bremen is a technology hub—from Airbus to many midsized firms in the aerospace sector. If your company develops patents, software, or other IP rights, a Maltese IP company can manage your licensing income in a tax-optimized way. Malta doesn’t offer a classic IP box regime like some countries, but the combination of low rates and EU legal security more than makes up for it.

EU Holding Solutions: When Bremen Meets Malta

The real strength of Maltese structures comes from combining them with German holdings. As a Bremen entrepreneur, you can set up a dual structure that leverages the strengths of both locations.

The Classic Bremen-Malta Structure

Here’s how it works: you keep your operating GmbH in Bremen (for clients, employees, and local business) and set up an additional Maltese company for international activities. The Bremen holding coordinates both entities and benefits from the EU Parent-Subsidiary Directive. This structure works especially well for:

• Bremen-based mechanical engineering firms with export business
• IT businesses from Bremen’s Technology Park
• Trading companies operating through Bremen’s port
• Consultancies with international clients

Splitting Substance: The Best of Both Worlds

You don’t have to move everything to Malta. The smart choice is to split functions: Remain in Bremen: – Operational business activities – German clients and suppliers – Research and development – Production facilities Move to Malta: – Holding functions – International contracts – Licensing deals – Group financing

Transfer Pricing: The Challenge of Being at Arm’s Length

Here’s where it gets technical: you need to ensure that all transactions between your Bremen-based and Maltese companies are carried out at arm’s length prices. The German tax office will scrutinize whether too much profit is being shifted to Malta. An experienced tax advisor in Bremen with Malta expertise will prepare the necessary transfer pricing documentation. While this comes with a cost, it’s crucial for a robust structure.

Finding a Tax Advisor in Bremen with Malta Expertise

Not every tax advisor in Bremen is familiar with Maltese structures. Most firms focus on traditional German tax advisory. For Malta projects, you’ll need specialists.

What Your Bremen-Based Tax Advisor Must Offer

A skilled Malta tax advisor in Bremen should have the following expertise:

• In-depth knowledge of Maltese tax law
• Experience with EU holding structures
• Transfer pricing know-how
• Contacts with Maltese partner firms
• Understanding of international compliance issues

Be sure to ask for references and past Malta projects. A good advisor should be able to tell you about at least three comparable cases from their portfolio.

The Cost Question: What Malta Advice Costs in Bremen

Expect higher hourly rates than standard tax consulting. Malta expertise is usually €250 to €400 per hour. For a complete structural advisory package, you should budget €5,000 to €15,000—depending on the complexity of your case.

Bremen Firms vs. International Players

You have the choice between established Bremen-based firms with a Malta division and specialized international consultants. Local firms better understand your business and the specific Bremen context. International players often have more Malta experience, but are more impersonal and pricier. My tip: Start with a local Bremen firm that works with Maltese partners. That way, you’ll get personal service on site plus access to Malta expertise.

Putting It into Practice: Your Path from the Weser to the Mediterranean

Theory is one thing, but how does it work in practice? From first idea to a functioning Malta structure usually takes three to six months. Here’s your roadmap:

Phase 1: Analysis and Planning (4-6 weeks)

Before setting anything up, the overall structure has to make sense. Your Bremen tax advisor will analyze your existing company and design a tailored Malta solution. Typical checkpoints: – Is your business model suitable for Malta? – Which functions can be moved? – What tax savings are expected? – What compliance requirements arise? Result of this phase: A detailed structural concept with cost-benefit analysis.

Phase 2: Incorporation in Malta (6-8 weeks)

With the concept ready, it’s time to set up the company. Since you won’t be relocating to Malta full time, your Bremen advisor will work with local Maltese partners. What happens in Malta:

1. Reservation of company name
2. Appointment of a local managing director
3. Leasing office space
4. Opening a bank account
5. Tax registration

Most formalities can be handled remotely. A visit to Malta is usually needed only to open the bank account.

Phase 3: Integrating the Structures (4-6 weeks)

Now your Bremen company is linked with the Maltese one. This is often the most complex stage, as both tax regimes must fit together smoothly. Key steps: – Amending company agreements – Establishing transfer pricing arrangements – Setting up new accounting processes – Training employees

Common Pitfalls in Implementation

From experience, Malta projects usually fail at the same points: Underestimated compliance costs: Malta structures aren’t “set and forget.” You need ongoing administration in both countries. Budget at least €15,000–25,000 per year for professional management. Unrealistic profit shifting: The German tax office is no fool. If you shift 90% of your profits to Malta without real substance there, you’re in for trouble. Lack of documentation: Every transaction between your companies must be traceable and arm’s length. Impeccable documentation is priceless during a future tax audit.

Costs and Time Investment: What Malta Structures Really Cost

Malta structures aren’t cheap. But if implemented properly, they pay off quickly. Here are the realistic numbers:

One-Time Setup Costs

Total investment: €15,000–28,000 for a professional Malta structure.

Ongoing Annual Costs

The running costs are the key factor in profitability:

• Tax advice in Bremen: €8,000–15,000
• Malta administration: €6,000–12,000
• Managing director in Malta: €8,000–15,000
• Office costs in Malta: €3,000–6,000
• Compliance & reporting: €4,000–8,000

Total annual costs: €29,000–56,000

Break-Even Analysis for Bremen-Based Businesses

Malta structures only make sense above a certain scale. The rule of thumb: – At €100,000 profit: Malta structures usually not profitable – At €250,000 profit: Borderline case, individual review needed – At €500,000 profit: Malta structure is very likely profitable – At €1 million profit: Malta structure almost always makes sense For example: your Bremen business makes €500,000 profit. In Germany, you’d pay about €150,000 tax (30% effective). With a Malta structure, you could reduce this to €75,000. Saving: €75,000. Subtract €45,000 additional costs, you’re left with €30,000 net savings—year after year.

Legal Pitfalls: What Bremen-Based Companies Need to Watch Out For

Malta structures are legal and EU-compliant—but only if set up correctly. As a Bremen entrepreneur, there are specific issues you need to consider.

Permanent Establishment Risk: When Malta Becomes Taxable in Bremen

It gets tricky if your Malta company inadvertently creates a permanent establishment in Bremen. This can happen faster than you think:

• Ongoing business activity from Bremen
• Employees based in Germany
• Long-term project work on site
• Stock kept in Germany

The solution: clearly separating the functions of your German and Maltese operations. Your Bremen tax advisor will develop the appropriate policy.

CFC Rules: When Germany Grabs Profits Anyway

Germany has a trump card against profit shifting: CFC (controlled foreign corporation) rules under the AO. These apply if: – The Malta company mainly generates passive income – Its tax burden is below 25% – You own more than 1% as a German shareholder Protecting Yourself from CFC Tax:

1. Prove real business activity in Malta
2. Employ qualified staff on-site
3. Let decisions be made independently
4. Build substantial substance

BEPS and EU-ATAD: New Hurdles for Malta Structures

International anti-avoidance rules have become stricter. Since 2022, more stringent substance requirements apply. Your Malta company must be able to prove real economic activity. Practical consequences for Bremen-based businesses: – More qualified staff needed in Malta – Higher substance requirements – More detailed documentation obligations – Regular compliance audits

Disclosure Obligations: What You Must Report to the German Tax Office

Transparency is key. As a Bremen entrepreneur with Malta holdings, you face extensive reporting requirements:

• German Foreign Tax Act: Declare any shareholding in a Maltese company
• Country-by-Country Reporting: If group turnover exceeds €750 million
• Capital Movement Act: Report cross-border transactions
• EU Savings Directive: Disclose interest income

Miss any reports and you could face tough penalties. A professional Bremen-based tax advisor with Malta experience knows all the deadlines and forms inside out.

Frequently Asked Questions from Bremen Entrepreneurs About Malta Tax Models

Can I use Malta structures as a sole proprietor from Bremen?

In principle yes, but not directly. You would first need to set up a German GmbH, which could then invest in Malta. For smaller profits (below €250,000), costs usually outweigh the benefits.

Do I personally need to move to Malta?

No, you can continue living in Bremen. Your Malta company does, however, need a local managing director and genuine substance on site. Regular visits for board meetings are usually still necessary.

How long does it take to set up a Malta structure?

From first consultation to a functioning structure usually takes 3–4 months. The Malta incorporation itself takes only 6–8 weeks, but planning and integration need time.

What happens during a tax audit in Bremen?

With proper documentation and genuine Malta substance, tax audits are straightforward. Only sham structures without real business activity in Malta lead to trouble.

Can I move my existing GmbH from Bremen to Malta?

Direct relocation is complicated and rarely beneficial. It’s better to set up a parallel structure and split functions between Bremen and Malta.

Which business models work best with Malta?

Trading companies, consultancies, IT firms, and holdings benefit the most. Manufacturing businesses or purely local service providers benefit less.

Is Malta still attractive after Brexit?

Malta is an EU member and unaffected by Brexit. In fact, its attractiveness has increased, as Malta is one of the few English-speaking EU jurisdictions.

How much does ongoing administration of a Malta company cost?

Plan for €25,000–50,000 annually for professional management, tax advice, and compliance in both countries. These costs are tax deductible.

Can the German tax office attack my Malta structure?

Not if it’s done correctly with real substance. Only sham setups lacking genuine business ties to Malta are problematic.

Do I need a tax advisor in both Bremen and Malta?

Yes—for optimal support, you’ll need expertise in both countries. Many Bremen firms cooperate with Maltese partners.

How quickly does a Malta structure pay off?

For profits over €500,000 usually within 1–2 years. For smaller profits, it can take longer or may not pay off at all.

What happens if tax laws change?

Malta structures are flexible and can be adapted. If major changes occur though, a reorganization may be necessary. That’s why ongoing advice is essential.