Tax Advisor Wiesbaden Malta: Your Guide to EU Tax Benefits

Im currently sitting in a café on Wilhelmstraße in Wiesbaden, reflecting on how much my life has changed since I relocated my company to Malta. Three years ago, I was just one of many entrepreneurs in Hesses capital, counting every euro twice before the tax office got its share. Today? 5% corporate tax in Malta instead of 30% in Germany. It sounds too good to be true—but it really isn’t, if you find the right tax advisors in Wiesbaden who understand Malta’s tax advantages.

Why am I sharing this? Because every day I get messages from Wiesbaden business owners asking the same questions: “Is Malta really legal?” “Which tax advisor in Wiesbaden actually knows about this?” “Is it worth it for my business?” The answers are more complex than you might think—but it can be done if you know how.

Leveraging Malta Tax Advantages in Wiesbaden: An Overview

Let me clear up a common myth right away: Malta is no longer a tax haven, but a regular EU member state with transparent tax rules. Thats actually a bonus for us in Wiesbaden because legal certainty is assured. You’ll still save a lot on taxes—if you do it right.

Why is Malta so attractive for Wiesbaden businesses?

The corporate tax rate in Malta is 35%—not so appealing at first glance, right? Heres the trick: Under Malta’s tax credit system, you get 6/7 of the tax paid refunded when you distribute profits. Effectively, you pay only 5% corporate tax. This isnt a loophole—it’s Maltese law.

For a Wiesbaden business with €100,000 profit, that means: instead of €30,000 tax in Germany, you pay only €5,000 in Malta. That’s €25,000 per year in savings. For me, the Malta structure paid for itself in the very first year.

Key Malta Tax Advantages in Detail

• 5% effective corporate tax thanks to the refund system
• No withholding tax on dividends, interest, and royalties
• Holding privile: Capital gains from holdings are tax-free
• EU law: Full legal certainty and double tax treaties
• Residency programs: Also attractive for individuals

The best part: You dont have to move to Malta. I still run my operating business out of Wiesbaden. The Maltese company is simply the holding structure above it.

Substance Requirements: What You Really Need

This is where it gets serious: German tax authorities—including Wiesbaden—look closely to see if your Malta structure has real economic substance. Mailbox companies are a thing of the past, thanks to the new EU guidelines. Youll need:

1. Management on site: At least board meetings in Malta
2. Office space: Doesn’t have to be big, but must be real
3. Local employees: At least a part-time employee
4. Operational activities: Real business decisions made in Malta

Does it sound complicated? It is—which is why you need experienced tax advisors in both Wiesbaden and Malta. I work with a team that coordinates both the German and Maltese side.

Tax Advisors in Wiesbaden for Malta: The Top Firms

Not every tax advisor in Wiesbaden knows about Malta. I had to learn this the hard way when my first advisor told me, “Malta? We don’t do that.” Now I know: You need specialists who understand both tax systems and regularly work with international structures.

What to Look for When Choosing

A good Malta tax advisor in Wiesbaden should meet these criteria:

• Documented Malta experience: At least 10 active Malta clients
• International cooperation: Partners in Malta and other EU countries
• CRS and BEPS knowledge: Up-to-date on new EU transparency rules
• Industry expertise: Understanding of your business model
• Proactive advice: Not just tax returns, but structural optimization

The Wiesbaden Tax Advisory Landscape

As the state capital of Hesse, Wiesbaden has a diverse tax advisory scene. Particularly in the city center—between Wilhelmstraße and Rheinstraße—youll find established firms with an international focus. Wiesbaden’s proximity to Frankfurt am Main—just 40 kilometers away—also provides access to the major international consulting groups.

First Consultation: The Right Questions to Ask

When you book an appointment with a tax advisor in Wiesbaden, ask the following questions:

1. “How many Malta structures have you set up in the past two years?”
2. “Do you work with partner firms in Malta?”
3. “What is your view on the new EU substance requirements?”
4. “Can you provide a reference—anonymously, of course?”
5. “What does ongoing support for a Malta holding cost?”

In my experience: Good advisors give concrete, honest answers. If you only get vague responses or the advisor seems to treat Malta as just something on the side, keep looking.

Wiesbaden–Malta Cooperation

You’ll get the best results with a consulting team that has a presence in both Wiesbaden and Malta. I’ve worked with such a setup for two years:

• Tax advisor in Wiesbaden: Manages German compliance, DTT application, audit readiness
• Malta tax advisor: Optimizes the Maltese structure, coordinates with the Malta Financial Services Authority (MFSA)
• Corporate services provider in Malta: Handles day-to-day implementation, secretary services, compliance

It costs more than a single advisor, but you’ll save yourself expensive mistakes and back payments down the road.

EU Holding Wiesbaden–Malta: How It Works in Practice

Now let’s get specific: How do you, as a Wiesbaden entrepreneur, set up a legally secure and tax-optimized Malta holding structure? Here are the most proven models I’ve seen in recent years.

The Classic Malta Holding Model

The EU holding structure works like this: You establish a Maltese company (usually a Limited Liability Company) that holds your German or other EU interests. Profits flow via dividends to the Malta holding and are taxed there at the favorable Maltese rate.

Here’s the typical structure for an entrepreneur from Wiesbaden:

1. You as an individual (resident in Wiesbaden)
2. Malta Holding Ltd. (you own 100%)
3. German operating GmbH (Malta holding owns 100%)

Profit moves from the German GmbH to the Malta holding (5% withholding tax thanks to the double tax treaty), is taxed there at an effective 5%, and can then be distributed to you. In Germany you only pay the difference to the flat tax (25%)—i.e., 20% on the dividend.

Substance Requirements in Practice

To make it work, your Malta holding must have real economic substance. Since the EU anti-tax avoidance directives, this is not a nice-to-have but mandatory. Specifically, this means:

Altogether, budget €20,000–40,000 per year to operate a substantial Malta holding. It sounds like a lot, but it makes sense from profits of around €150,000 per year.

Special Case: IP Holding for Digital Business Models

Malta is especially interesting for Wiesbaden entrepreneurs with digital business models. You can transfer your intellectual property (software, brands, patents) to a Malta holding and then have license fees paid.

Here’s how it works: Your German GmbH pays license fees to your Malta holding for using your software or brand rights. These fees are tax-deductible in Germany (reducing German profits) and taxed at just 5% in Malta.

• Advantage: Highly effective profit shifting possible
• Disadvantage: High substance requirements, as IP structures are scrutinized closely
• Suitable for: SaaS businesses, e-commerce, app developers

The Malta–Germany Double Tax Treaty

One reason Malta is so attractive for Germans: The double tax treaty (DTT) between Germany and Malta works smoothly. Since 2001, clear rules define who pays tax where.

The key points of the DTT:

• Dividends: 5% German withholding tax if you hold over 10% (parent-subsidiary directive)
• Interest: 0% withholding tax for business relationships
• Royalties: 0% withholding tax
• Business profits: Taxation in country where activities are carried out

This means: As long as your Malta holding has real substance and carries out operational activities, taxation in Malta is legitimate—even from a German perspective.

From Wiesbaden to Malta: Your Step-by-Step Guide

Enough with theory—let me show you how to actually build a Malta structure from Wiesbaden. I’ve been through the process myself and made every mistake imaginable. Here’s what I learned so you can do better:

Phase 1: Preparation and Planning (4–6 Weeks)

Weeks 1–2: Find a Tax Advisor and Initial Consultation

Find an experienced tax advisor in Wiesbaden who understands Malta structures. The initial consultation should clarify:

• Is your business model suitable for Malta?
• What substance requirements apply in your case?
• What’s the optimal structure?
• What are the estimated total costs?
• What are the ongoing compliance requirements?

Weeks 3–4: Due Diligence and Business Plan

Now it gets serious: You must show that your Malta holding has legitimate business reasons. The German tax office will check this at the latest in your next audit. Prepare:

1. Business case: Why do you need a Malta holding? (Expansion, financing, M&A)
2. Proof of substance: How do you ensure real business activity in Malta?
3. Tax ruling: Optional but recommended—advanced agreement with the Maltese authorities

Weeks 5–6: Choosing Partners in Malta

You need reliable partners in Malta. My recommendations:

• Malta tax advisor: For tax advice and MFSA contacts
• Corporate services provider: For setup and ongoing administration
• Lawyer: For company law and contracts
• Bank: Opening an account can take months—start early!

Phase 2: Company Formation (6–8 Weeks)

Founding the Maltese Company

You can set up a Maltese Limited Liability Company in about 2–3 weeks, provided all documents are on hand. Requirements:

Opening a Bank Account: The Toughest Part

This is where many stumble: Opening a bank account in Malta has become extremely complicated due to stricter anti-money laundering rules. Allow at least 2–3 months and always have a backup plan. Most German entrepreneurs end up at:

• Bank of Valletta (BOV): Malta’s largest bank, conservative but reliable
• HSBC Malta: Internationally positioned, strict requirements
• APS Bank: Smaller, often more flexible for SMEs

Alternatively, many now use European neobanks like Revolut Business or Wise, both of which accept Malta entities.

Phase 3: Ongoing Operations

Building Substance

This is the most crucial stage: You must establish real business activity in Malta. That doesn’t mean you have to move, but the holding needs true operational substance:

1. Regular board meetings: At least four per year, recorded
2. Real business decisions: Investments, financing, M&A executed via Malta
3. Local staff: At minimum a qualified company secretary or director
4. Documentation: Keep records for future audits

Ongoing Compliance

A Malta holding means double compliance burdens—in both Malta and Germany:

• Malta: Annual accounts, tax returns, annual return to MFSA
• Germany: Check attribution taxation, fiscal code filings, CRS compliance
• EU-wide: DAC6 reports for cross-border structures

Costs and Effort: Realistic Numbers for Wiesbaden Entrepreneurs

Let me be honest: A Malta holding isn’t cheap. The days when you could set up a mailbox company for a few thousand euros are over. Now you need real substance—and that costs money. Here’s what I’ve experienced:

One-Time Setup Costs

Ongoing Annual Costs

The ongoing costs are the real hurdle. Here’s what truly determines if Malta is worthwhile for you:

• Tax advisory Germany: €8,000–15,000 (depending on complexity)
• Malta tax compliance: €5,000–12,000
• Company secretary: €2,000–5,000
• Office/registered office: €3,000–8,000
• Local staff: €12,000–25,000 (part/full-time)
• Banking and admin: €2,000–5,000
• Travel costs to Malta: €3,000–8,000 (for meetings and substance)

Total annual costs: €35,000–78,000

Break-Even Calculation for Wiesbaden Entrepreneurs

The big question: At what profit level does Malta make sense? Here’s a realistic calculation:

My rule of thumb: Malta makes sense starting from around €200,000 annual profit. Below that, compliance costs eat up the tax savings.

Hidden Costs That Are Often Overlooked

Here are a few cost traps that caught me unaware at first:

• CRS compliance: €2,000–5,000 for automatic information exchange
• Transfer pricing documentation: €5,000–15,000 for group-internal transactions
• Audit preparation: €10,000–25,000 if audited by the German tax office
• Currency risk: Malta uses the euro, but exchange rate swings abroad
• Reputation costs: Some German clients/partners are skeptical about Malta structures

Financing the Malta Structure

Not everyone has €30,000 setup costs plus €50,000 annual costs just lying around. Here are some financing options I’ve seen:

1. Self-financing: From past years’ profits
2. Shareholder loans: You lend money to your Malta holding
3. Bank financing: Tough, but some banks support international structures
4. Investor: Silent partner sharing in the tax savings

I financed my Malta structure from the savings made in the first six months. It was a calculated risk that paid off.

Common Pitfalls in Malta Tax Planning

After three years of Malta experience I can say: Most mistakes don’t happen during setup, but in the day-to-day running. Here are the stumbling blocks I’ve encountered or seen others fall into:

Pitfall 1: Lack of Substance

The most common and expensive mistake: Thinking a Maltese company with a German director and administration is enough. Wrong! The German tax office now checks very closely for real substance in Malta.

What goes wrong:

• All decisions still made back in Wiesbaden
• No real office in Malta, only a mailing address
• No local employees or service providers
• Board meetings are only on paper

Consequences: Attribution taxation—you’ll pay German tax on Maltese profits, including back payments plus 6% interest per year. For me, that would have cost €180,000.

How to avoid it: Invest in real substance from day one. I fly to Malta every two months, hold board meetings and make key decisions there. It costs time and money, but it’s legal and safe.

Pitfall 2: CRS & Automatic Information Exchange

Since 2017, EU countries automatically exchange tax data. Many still think Malta is a secret tax haven. That’s nonsense—and dangerous.

What happens: Your Maltese bank automatically reports all account details to the German tax authorities. The Wiesbaden tax office knows exactly what’s happening in your Malta accounts.

Common mistakes:

• Unreported foreign accounts (penalty: 25% of account balance)
• Incorrect disclosure on tax returns
• Ignoring CRS reports

My tip: Clean documentation from day one. I report all Malta accounts in Germany and document every money flow. Transparency is your friend, not your enemy.

Pitfall 3: Transfer Pricing in Group Transactions

If your German GmbH transacts with your Malta holding (loans, licenses, management fees), you have to prove the prices are at arms length. That’s called transfer pricing.

Typical problems:

• License fees to Malta holding set too high
• Shareholder loans with rates set too low
• Excessive management fees
• No benchmarking studies

The cost: During an audit, the tax office may adjust your transfer pricing. From €50,000 in license fees, perhaps only €20,000 are accepted. The shortfall is treated as a hidden profit distribution—26.375% tax plus solidarity surcharge.

Solution: Professional transfer pricing documentation. It costs €5,000–15,000, but saves a lot of hassle later. I update my TP documentation every two years.

Pitfall 4: Brexit and UK Connections

Malta was a British colony, and many structures still have UK links. Since Brexit, that’s become problematic.

Problems:

• UK directors lose EU status
• UK banks close Malta accounts
• UK legal entities no longer EU-compliant
• New tax treaties needed

My advice: Avoid UK ties altogether. Use Maltese or EU directors, EU banks, and EU legal forms. That’s future-proof.

Pitfall 5: Reputation Risks in Germany

A frequently underestimated risk: Some German business partners, banks, or clients are skeptical regarding Malta structures. This can impact your business.

What I’ve experienced:

• German bank wanted to end business relationship
• Large client questioned “tax avoidance”
• Competitors used Malta structure for negative PR
• Compliance departments cautious with Malta firms

Strategies:

1. Transparency: Proactively explain why you use Malta (expansion, financing—not just taxes)
2. Compliance: Show you’re following all rules
3. Diversification: Don’t run all business through Malta
4. PR strategy: Shape a positive narrative (international growth, EU expansion)

Frequently Asked Questions: Wiesbaden–Malta Tax Advisors

Can I, as a Wiesbaden entrepreneur, really pay only 5% tax in Malta?

Yes, but only under certain conditions. The 5% effective corporate tax rate applies only when you actually distribute profits and your Malta company has real economic substance. You first pay 35% Maltese corporate tax, but get 6/7 back (i.e., about 30% of 35%) when you pay out dividends. What’s left: a 5% effective tax burden.

Which tax advisors in Wiesbaden really have Malta experience?

Not every tax advisor in Wiesbaden knows Malta. Look for these criteria: At least 10 active Malta placements, partnerships with Malta firms, proven record with international structures. Ask for references and how many Malta holdings they’ve set up in the past two years. Good advisors answer specifically and honestly.

How long does it take to set up a Malta holding from Wiesbaden?

Plan on 3–4 months for a full Malta structure. Setting up the company takes 2–3 weeks, but opening the bank account can take 2–3 months. The most time-consuming part is usually preparation: finding a tax advisor, planning structure, choosing Malta partners, developing your business case. Allow at least six months from the first consultation to an operational Malta holding.

What does a Malta holding realistically cost per year?

Expect €35,000–78,000 in annual costs for a substantial Malta holding. This includes: German tax advisory (€8,000–15,000), Malta tax compliance (€5,000–12,000), local staff (€12,000–25,000), office/administration (€3,000–8,000), company secretary (€2,000–5,000), banking and travel costs. Plus, one-off setup costs of €15,000–60,000.

At what profit level is Malta worthwhile for Wiesbaden entrepreneurs?

Malta is worthwhile starting at around €200,000 annual profit. Below that, high compliance costs (€35,000–78,000 per year) eat up all tax savings. At €300,000 profit, you’ll save about €25,000 per year; at €500,000, it’s already €75,000. Break-even is around €200,000 a year—below that, Malta is a loss.

Is a Malta holding legal, or is it tax evasion?

Malta holdings are completely legal—as long as you follow the rules. Malta is an EU member state with normal tax rules, no longer a tax haven. What matters: real economic substance in Malta (office, local staff, business activity), correct reporting in Germany, and compliance with transfer pricing. Mailbox companies with no substance are illegal and will be penalized.

Do I have to move to Malta to run a Malta holding?

No, you don’t have to move to Malta. But your Malta company needs genuine substance on site: Maltese company secretary, office space, regular board meetings in Malta, operational business. I fly to Malta every two months for meetings and business decisions. You can keep living and working in Wiesbaden.

How does the German tax office react to Malta structures?

The German tax office scrutinizes Malta structures closely, but accepts them if implemented correctly. Critical points: real economic substance in Malta, correct transfer pricing for group transactions, accurate reporting. Malta holdings are often a focus in audits. Important: thorough documentation, professional advice, transparent communication with the tax office.

What is the optimal Malta structure for Wiesbaden IT companies?

For IT companies, an IP holding structure is often the best: Software, brands, or patents are transferred to the Malta holding, and the German GmbH pays license fees. This allows highly effective profit shifting. Caution: IP structures have especially high substance requirements. Real development activities or IP management in Malta are needed.

Can small Wiesbaden businesses benefit from Malta structures?

Malta only makes sense starting from around €200,000 annual profit. Smaller businesses should consider alternative tax optimizations: investment deductions, provisions, or tax-optimized legal forms. For many small businesses, Malta compliance costs (€35,000–78,000 yearly) are higher than the tax savings. Do the math realistically before making a decision.

What happens if there’s a tax audit involving Malta?

Audits with Malta structures are more detailed and take longer. The tax office checks: economic substance of the Malta company, transfer pricing for group transactions, attribution taxation, CRS reports. Preparation is everything: full documentation, professional representation, a solid business case for the Malta structure. I recommend: audit insurance and an experienced tax advisor.

What alternatives to Malta exist for Wiesbaden entrepreneurs?

Other EU countries with attractive tax rates: Ireland (12.5% corporate tax), Netherlands (holding privilege), Luxembourg (IP box regime), Cyprus (12.5% corporate tax). Germany also offers optimizations: profit retention benefits, investment deductions, tax-efficient legal forms. Most important: Your business model, profit levels, and international orientation determine the best structure.