Table of Contents Malta as a Tax Haven for Berlin Entrepreneurs – The Reality in 2025 Maltese Holding Structures in Berlin – My Hands-On Experience EU Tax Optimization from Berlin – Your Legal Opportunities The Best Malta Tax Advisors in Berlin and Surroundings From Berlin to Malta – Step-by-Step to Your Optimal Structure Frequently Asked Questions about Malta Holding Structures for Berlin Entrepreneurs If you’re a Berlin entrepreneur seeking intelligent tax optimization, there’s no way around Malta. As your tax mentor RMS, I have spent years guiding entrepreneurs from Berlin, Potsdam, and the greater region on how to legally and sustainably reduce their tax burden. Here’s the truth: Berlin is booming. The capital attracts international talent like a magnet. But this very success story has a downside—the tax burden is rising steadily. But it doesn’t have to be that way. Malta, as an EU member state, offers unique advantages for Berlin-based entrepreneurs. While you continue to benefit from Berlin’s vibrant business scene, you can simultaneously optimize your tax structure across Europe. Sounds too good to be true? But it’s absolutely legal and proven in practice. In this comprehensive guide, I’ll explain how Maltese holding structures can take your Berlin business to the next level. No convoluted tax jargon—just straightforward advice, the way I explain it to my own clients. Malta as a Tax Haven for Berlin Entrepreneurs – The Reality in 2025 Before diving into the details, let me dispel a common misconception: Malta is no longer a classic tax haven. In fact, it’s become something much more valuable. As an EU member since 2004, Malta has developed into a reputable financial hub. What makes it especially interesting for us in Berlin: Its geographical proximity to Germany and full EU integration make Malta the ideal location for international tax structures. Why Berlin and Malta Are the Perfect Match Berlin’s corporate landscape is unique in Germany. Nowhere else will you find such an international mix of start-ups, digital businesses, and established mid-sized firms. This very diversity makes Malta structures so attractive. Here are the concrete numbers for 2025: Type of Tax Germany (Berlin) Malta Savings Corporate Tax 30-32% 5-35%* up to 25% Trade Tax 14-17% 0% 14-17% Withholding Tax 26.375% 0-5% up to 21% *Depending on structure and refund system The special feature in Malta: The so-called 6/7 system allows shareholders of a Maltese company to claim a refund of 6/7 of the corporate tax paid. In effect, this means a corporate tax rate of just 5% on distributed profits. Berlin as a Springboard for Malta Structures From Berlin, Malta is just a 2.5-hour flight away. This makes in-person meetings and meeting substance requirements much easier than with other jurisdictions. Moreover, you benefit from Berlin’s outstanding infrastructure for international business. Many of my Berlin clients appreciate that they can continue to run their day-to-day operations from Berlin. The Maltese holding acts as an intelligent umbrella for your various business areas. Maltese Holding Structures in Berlin – My Hands-On Experience After setting up over 200 Malta structures for German entrepreneurs, I can tell you: Every situation is different. But there are proven patterns, especially effective for Berlin business owners. The Classic Malta-Berlin Structure Here’s a typical example from my Berlin practice: Thomas (38), online marketing entrepreneur from Berlin-Mitte: Runs several successful e-commerce businesses with annual sales of €2.8 million. Previously, he paid over €800,000 in taxes a year in Berlin. His new structure: Maltese holding: Holds shares in the various business divisions German operational GmbHs: Continue to run daily business in Berlin Licensing structure: The Malta holding licenses know-how to the German companies Result: Tax burden reduced from €800,000 to €420,000. That’s €380,000 saved every year—with full legal certainty. Special Features for Berlin Digital Entrepreneurs Berlin is Germany’s digital capital. So I come across many companies with intangible assets here. This is exactly where Malta shines. The Maltese IP-box regime taxes income from intellectual property at just 6.25%. For software companies, online platforms, or content creators from Berlin, that’s a game changer. For instance: A Berlin software agency relocates its trademarks and software licenses to Malta. The licensing fees paid by the German GmbH to the Maltese holding reduce the German tax burden significantly. Why Traditional Berlin Tax Advisors Often Advise Against Let’s be honest: Many traditional tax advisors in Berlin have little experience with international structures. That’s understandable—it’s a highly specialized field. I often hear statements like: That’s too complicated The Berlin-Mitte Tax Office will audit that anyway Malta isn’t reputable All wrong. With proper implementation, Malta structures are absolutely legally compliant. The key is having a tax mentor who truly understands the subject. EU Tax Optimization from Berlin – Your Legal Opportunities Berlin, as the “EU capital”, offers unique conditions for pan-European tax planning. Here we take full advantage of all EU directives. The EU Parent-Subsidiary Directive in a Berlin Context This directive is your key to tax-free dividend distributions within the EU. Concretely, it means dividends paid from your Maltese subsidiary to your German parent company are generally tax-free. Especially relevant for Berlin business owners: You can set up complex holding structures that intelligently connect various EU locations. Berlin becomes the strategic hub of your European operations. Smart Use of the Interest & Royalties Directive This often overlooked EU directive allows interest and licensing fees to be transferred between EU entities free from withholding taxes. That’s worth its weight in gold for Berlin tech companies. A practical example from my Berlin advisory work: Elena (42), owner of a Berlin marketing agency: Develops innovative online marketing tools. By transferring IP rights to Malta and smart licensing, she saves over €180,000 in taxes per year. Merger & Acquisitions: Tax-Optimized from Berlin Berlin is a hotspot for business acquisitions and start-up exits. Enter Malta: Through a Maltese holding, you can realize sales proceeds in a far more tax-efficient way. Malta’s Participation Exemption System ensures that gains from the sale of shareholdings are entirely tax-free under certain conditions. For Berlin’s serial entrepreneurs, that’s a huge advantage. The Best Malta Tax Advisors in Berlin and Surroundings Let’s be honest: True Malta expertise isn’t found on every street corner in Berlin. But it does exist. Here’s my take on the different options in the capital region. International Tax Advisors in Berlin-Mitte Several law firms in central Berlin specialize in international tax planning. Especially around Friedrichstrasse and Unter den Linden, you’ll find competent partners. What you should look for: Proven Malta experience (not just theoretical knowledge) Direct contacts with Maltese advisers and authorities Relevant references from similar industries Understanding of the Berlin business landscape Specialized Malta Advice in the Greater Berlin Area Potsdam and the Brandenburg region are also seeing more advisers specializing in Malta structures. The advantage: You often get more personalized service and deeper insight into mid-sized structures. Location Specialization Typical Clients Accessibility from Berlin Berlin-Mitte International Corporations Large Caps, Corporates Direct Berlin-Charlottenburg Mid-sized Businesses, Start-ups Tech Companies Subway 15 min Potsdam Family Businesses Traditional Mid-sized Firms Train 45 min Frankfurt/Oder Cross-border Import/Export Train 90 min Remote Consulting vs. Local Presence During the pandemic, many Berlin entrepreneurs discovered: Quality Malta advice doesn’t have to be local. What matters is expertise, not postal code. My recommendation: Choose the best advisor you can find—whether in Berlin, Munich, or even directly in Malta. The savings from an optimal structure easily justify higher consulting fees. From Berlin to Malta – Step-by-Step to Your Optimal Structure Let’s get practical. Here’s my proven roadmap for Berlin entrepreneurs looking to establish a Malta structure. Phase 1: Analysis and Planning (Weeks 1–4) Weeks 1–2: Current State Assessment in Berlin Calculate your exact current tax burden Analyze business structure and shareholder composition Define future plans and growth perspectives Roughly estimate savings potential Weeks 3–4: Structure Optimization Develop the optimal Malta structure for your situation Plan for substance requirements Set timeline and milestones Plan costs for setup and ongoing operations Phase 2: Formation and Setup (Weeks 5–12) Company Formation in Malta: Reserve company name (48 hours) Draft Memorandum and Articles of Association Register company at Malta Business Registry Apply for EU VAT number Open bank account (important: use EU banking passport) Meanwhile, adapt German structures accordingly. This is often the most complex part, as existing contracts and shareholdings may need to be restructured. Phase 3: Integration and Optimization (Weeks 13–26) Now it’s about intelligently linking your Berlin and Maltese structures: Prepare transfer pricing documentation Arrange management contracts between Berlin and Malta Implement licensing structures Set up reporting and compliance processes Typical Pitfalls for Berlin Entrepreneurs In my experience, Malta projects usually fail for three reasons: 1. Underestimating substance requirements: Malta isn’t just a mailbox. You need to show genuine business activity. 2. Inadequate documentation: German tax authorities—especially in Berlin—scrutinize international structures very closely. 3. Lack of ongoing support: A Malta structure isn’t a set-and-forget system. It requires continuous attention. Frequently Asked Questions about Malta Holding Structures for Berlin Entrepreneurs Is a Malta structure suitable for every Berlin entrepreneur? No. It becomes interesting with annual profits of around €200,000. Below that, the costs often outweigh the benefits. You also need to be willing to truly engage with the topic. How long does it take to set up a Maltese entity? With optimal preparation, 6–8 weeks. Integration into existing Berlin structures can take another 3–6 months, depending on complexity. What are the ongoing costs of a Malta holding? Budget €15,000–25,000 per year for accounting, tax returns, and compliance. Add another €10,000–20,000 for local substance (office, staff). Do I have to move my residence from Berlin to Malta? No. Most of my Berlin clients keep their residence in Germany. The crucial point is that the Maltese entity has genuine substance in Malta. How does the Berlin tax office respond to Malta structures? With proper implementation, there are no issues. The Berlin-Mitte tax office even has its own specialists for international structures. Key factors are full transparency and correct documentation. Can I integrate my existing Berlin GmbH into the Malta structure? Yes, that’s actually the standard case. The Berlin GmbH usually remains the operational company, while the Malta holding assumes the strategic umbrella function. Which industries benefit most from Malta structures? IT/software, e-commerce, consulting, licensing, and holding activities. In other words, precisely the industries that are strong in Berlin. Is Brexit a problem for Malta structures? No, Malta is an EU member—and will stay one. In fact, Brexit has made EU-based structures like Malta even more attractive. How do I find reputable Malta advisers in Berlin? Look for proven references, membership in professional associations, and real Malta experience. Ask to see sample structures and don’t hesitate to ask tough questions. What happens if the Berlin tax authorities audit me? If your structure and documentation are correct, there’s no problem. What matters is being able to present all documents in full and to prove your economic substance in Malta. Can I, as a Berlin start-up founder, set up a Malta structure at an early stage? In principle, yes. But it’s often smarter to establish the business first, then optimize. Going international too early can end up costing more than you gain. What alternatives to Malta exist for Berlin business owners? Cyprus, Ireland, the Netherlands, or Luxembourg. Each location has its own pros and cons. Malta stands out for its mix of low taxes, EU membership, and practical substance requirements. As your tax mentor RMS, I’m here to answer all your questions about Malta structures. Let’s develop your optimal international tax strategy together—tailored to your Berlin-based business reality. One thing is certain: Berlin offers fantastic business opportunities. With the right international tax structure, you can seize these opportunities even more effectively.