Tax Advisor Stuttgart Malta: Your Guide to EU Holding Structures

Malta Tax Consulting in Stuttgart: Why Companies from Baden-Württemberg Benefit

Stuttgart is Germany’s automotive capital. Mercedes-Benz, Porsche, Bosch—all have their roots here. But it’s not just the large corporations that benefit from the business environment. Medium-sized companies and start-ups are thriving in the region as well.

And here lies the problem: Success leads to high tax burdens. The business tax rate in Stuttgart is 420% of the base rate (as of 2024). Add corporate income tax and solidarity surcharge. Altogether, you’re quickly looking at an overall burden of 30% or more.

The Maltese Alternative: 5% Effective Tax Burden

Malta offers EU companies a completely different perspective. The Maltese tax system is based on a tax credit method. You initially pay 35% corporate tax. But here’s the kicker: When profits are distributed, you receive a refund of 6/7 of the tax paid.

Let’s do the math: On €100,000 in profit, you pay €35,000 in taxes. Upon distribution, you get €30,000 back. Your effective tax burden? Just €5,000 or 5%.

This means: Instead of paying €30,000 in Stuttgart, in Malta you pay only €5,000. That’s a saving of €25,000—for every €100,000 in profit!

Why Malta Is Especially Attractive for Stuttgart-Based Companies

Stuttgart is advantageously connected to Malta. Direct flights from Stuttgart to Malta take just 2.5 hours. For business meetings or administrative tasks, Malta is easily accessible.

Moreover, in Baden-Württemberg there’s an international mindset. Many entrepreneurs are already globally positioned. As a result, expanding to Malta is easier here than in other parts of Germany.

The Stuttgart Chamber of Industry and Commerce counts over 150,000 member companies (as of 2024). Roughly 60% are engaged in exports. These businesses can particularly benefit from Maltese structures.

Local Specifics for Baden-Württemberg Businesses

Baden-Württemberg has special regulations for international company structures. The tax authorities are experienced in handling EU holdings. This makes it considerably easier to implement Maltese structures.

Still, there are regional differences. Stuttgart Corporate Tax Office treats Malta structures differently from smaller local tax offices. Here, local expertise is essential.

The Best Maltese Tax Models for Stuttgart-Based Businesses

Not every Maltese tax structure fits every company in Stuttgart. The choice depends on your business model, industry, and personal objectives.

The Maltese Trading Company: Ideal for Trade Businesses

Trading companies from Stuttgart benefit particularly from Maltese trading companies. Why? Malta has double taxation agreements with over 70 countries. Your profits from international business aren’t subject to double taxation.

An example from practice: A Stuttgart-based engineering company sells via Malta to clients in Asia and America. Profits are only taxed in Malta—at an effective rate of 5%.

The structure is simple: Your German company is the operational entity. The Maltese company takes over distribution and profit recognition. Legal, transparent, and highly efficient.

The Maltese Holding: Perfect for Investment Structures

Stuttgart entrepreneurs with several companies or participations often rely on Maltese holdings. The benefit: Dividends between EU companies are tax-free (EU Parent-Subsidiary Directive).

Your Baden-Württemberg GmbH distributes dividends tax-free to the Maltese holding. The holding reinvests or distributes to you at just a 5% tax burden. An elegant solution for asset accumulation.

The Maltese IP Company: For Innovative Businesses

Baden-Württemberg is renowned for innovation. When it comes to licensing income, Malta offers significant advantages.

Intellectual property (IP) can be taxed at only 5% in Malta. Your Stuttgart company develops and manufactures; the Maltese IP company manages patents and licenses. The revenues are tax-optimized to Malta.

Which Model Fits Your Stuttgart-Based Business?

The decision depends on various factors. Trading companies work best with trading structures. Software firms use IP structures. Consulting firms choose service companies.

Company size also plays a role. Businesses with less than €250,000 in annual profits should carefully weigh cost versus benefit. Structure costs may range from €15,000 to €25,000 per year.

From €500,000 annual profit upwards, Maltese structures almost always pay off. The tax savings far exceed the costs.

EU Holding Structures from Stuttgart: Malta as a Strategic Partner

EU holding structures are the backbone of modern tax planning. Stuttgart, as an EU location, offers perfect conditions for such setups. Malta is an ideal complement to these structures.

The Germany-Malta Axis: How to Leverage the Best of Both Worlds

Germany offers legal certainty, a skilled workforce, and a stable market. Malta delivers low taxes and EU compliance. Why not combine the two?

Your operating company remains in Stuttgart. This is where you develop products, employ staff, and serve the German market. The Maltese holding takes over strategic functions: financing, licensing, international expansion.

Many Baden-Württemberg companies are already using this model—from start-ups in Cyber Valley to established automotive suppliers.

Practical Implementation for Stuttgart-Based Companies

Implementation is step by step. First, you establish the Maltese holding. It acquires shares in your German company. Alternatively, you can contribute shares.

Important: Substance requirements must be met. Your Maltese company needs actual business operations. A mere letterbox company is not enough.

In practice, that means: At least one managing director on site, an office, and regular board meetings. These requirements are achievable and affordable.

Financing Through the Maltese Holding

A smart component is financing. Your Maltese holding grants loans to the German company. Interest payments flow to Malta, where they’re taxed at just 5%.

At the same time, interest payments reduce the German company’s taxable profit. A win-win situation under EU regulations.

This is particularly attractive for Stuttgart-based companies. The high real estate prices in the region often require external financing. So why not structure it intelligently?

International Expansion via Malta

Malta is a springboard to international markets. The country has excellent connections to Africa, Asia, and the Middle East—thanks to its location in the Mediterranean.

Stuttgart-based companies use Malta as a base for non-EU business. Especially in automotive supply and engineering, this opens up interesting opportunities.

The Maltese company acts as a sales hub for international markets. Profits from these transactions are minimally taxed in Malta.

Tax Advisors for Malta Structures in Stuttgart and the Surrounding Area

The choice of the right tax advisor determines the success or failure of your Malta structure. Not every Stuttgart tax consultant understands international structures. Even fewer have expertise in Maltese setups.

What Sets Malta Specialists Apart from Traditional Tax Advisors?

Traditional tax advisors focus on German tax law. Malta specialists master the interfaces between German and Maltese tax regulations. They’re also aware of practical pitfalls.

For example: Controlled Foreign Corporation (CFC) taxation under German tax code. If structured incorrectly, it can ruin your entire Malta strategy. Malta specialists know how to avoid this trap.

They also work with Maltese partners—ensuring smooth communication and quick problem-solving.

What to Look for When Choosing an Advisor in Stuttgart

Check credentials. Has the advisor already managed successful Malta structures? Can they provide concrete examples?

Ask about their network. Do they work with Maltese lawyers and tax advisers? Without local partners, things get complicated.

Responsiveness is also key. Malta structures require ongoing support. An advisor who’s only available once a year won’t cut it.

Costs of Malta Consulting in the Stuttgart Region

Quality Malta consulting comes at a price. Expect €250 to €400 per hour for specialized advice. That may seem steep, but it’s an investment.

Structuring typically costs €15,000 to €35,000. Ongoing support amounts to €8,000 to €15,000 per year.

These costs pay off quickly. With €200,000 in annual profit, you can save about €50,000 in taxes. After just one year, you’ve recouped your investment.

Local Providers vs. International Law Firms

In Stuttgart you’ll find both local providers and branches of international law firms. Both options have pros and cons.

Local providers know the regional specifics. They’re familiar with how Stuttgart tax offices operate. You’ll enjoy more personal contact.

International firms often have greater Malta experience. Their structures are standardized and proven. But they’re usually more expensive and less personal.

My tip: Choose a local provider with international expertise. The best of both worlds.

Case Studies: How Companies from Baden-Württemberg Save with Malta

Theory is good, practice is better. Let me show you real-world examples from my consulting work. All names and details are, of course, anonymized.

Case 1: Stuttgart Software Start-Up Saves €180,000 Annually

A young software company from Stuttgart develops apps for the automotive industry. Annual revenue: €800,000, profit: €300,000. The German tax burden was €90,000.

The solution: A Maltese IP holding acquires the software licenses. The German company pays royalties to Malta, which are taxed at just 5% there.

The result: Instead of €90,000, the company pays only €15,000 in taxes. That’s a saving of €75,000 annually. Over three years: €225,000 more liquidity for growth.

Case 2: Region’s Engineering Company Optimizes Its Export Business

An established mechanical engineering firm from the greater Stuttgart area exports 70% of its products. Annual sales: €5 million, export profit: €800,000.

The challenge: High German taxes on export profits. The solution: A Maltese trading company handles international sales.

The German company manufactures and sells to the Maltese trading company, which in turn sells to international customers and generates the profits in Malta.

The result: €200,000 in annual tax savings. The company invests the saved funds in new machinery and jobs in Germany.

Case 3: Consulting Company Restructures Internationally

A consulting firm from Stuttgart advises international corporations. Annual turnover: €1.2 million, profit: €400,000. The problem: High German taxes and complicated international contracts.

The solution: A Maltese service company handles international mandates. The German entity focuses on the domestic market.

Advantages: Lower taxes in Malta (€20,000 instead of €120,000) and easier contract management thanks to EU law.

What These Cases Have in Common

All companies kept their operational base in Baden-Württemberg. No jobs were transferred abroad. On the contrary, the tax savings enabled investments and new hires.

The structures are legal and transparent. All companies reported and paid taxes on their Malta activities properly.

Important: These results are not guaranteed. Every case is unique. Careful planning and professional advice are essential.

Legal Fundamentals for Malta Structures in Baden-Württemberg

Legal certainty is absolutely essential for international tax structures. Entrepreneurs in Baden-Württemberg are particularly cautious—with good reason. Here are the key legal aspects for Malta structures.

EU Law as the Foundation

Malta has been an EU member since 2004. All Malta structures are based on EU law. This means: Freedom of establishment, free movement of capital, and freedom to provide services apply without restriction.

The EU Parent-Subsidiary Directive permits tax-exempt dividend distributions between EU companies. The Interest and Royalties Directive provides for tax-free interest payments.

These directives are implemented in German law. You can rely on their applicability.

German Foreign Tax Law: Know the Rules

The German Foreign Tax Act (AO §§ 7–14) governs international structures. Most important: Controlled Foreign Corporation (CFC) rules under § 8 AO.

These apply if your Maltese company doesn’t have actual business activity. In that case, Malta profits are taxed in Germany.

The solution: Build substance in Malta. A local managing director, an office, and actual business decisions on site are sufficient.

Germany–Malta Double Taxation Agreement

The DTA between Germany and Malta prevents double taxation. It governs which country may levy taxes.

Key point: The permanent establishment principle. Your Maltese company may not maintain a permanent establishment in Germany; otherwise, it becomes taxable here.

In practice, this means: Management and major decisions must take place in Malta.

Notification Requirements for Baden-Württemberg Businesses

Malta structures trigger various reporting obligations. You must observe these closely:

• Notification under § 138 AO when establishing foreign companies
• Disclosure of interests in foreign companies
• Information in the German tax return
• Balance of payments reporting for larger amounts

Failure to comply can result in hefty fines. Stuttgart’s tax office is particularly vigilant on this front.

Case Law on Malta Structures

German courts have repeatedly confirmed Malta structures. Key rulings:

The Federal Fiscal Court (BFH) clarified in 2019: EU-compliant Malta structures cannot be objected to (BFH ruling of 20.02.2019, I R 69/16).

These decisions provide legal certainty for entrepreneurs in Baden-Württemberg.

Frequently Asked Questions about Malta Tax Consulting in Stuttgart

Is a Malta Structure Legal for My Stuttgart-Based Company?

Yes, Malta structures are fully legal if set up correctly. Malta is an EU member and all structures are based on EU law. Adherence to substance requirements and German reporting obligations is crucial.

From What Profit Level Does a Malta Structure Make Sense for Companies from Baden-Württemberg?

As a rule of thumb: It gets interesting from €200,000 in annual profits, and almost always makes sense from €500,000 onwards. Annual structure costs are €15,000 to €25,000. With sufficient profit, the return on investment is rapid.

Do I Need to Move My Company Headquarters from Stuttgart to Malta?

No, your operational company can stay in Stuttgart. The Malta structure complements your German business, it doesn’t replace it. Jobs and production sites remain in Baden-Württemberg.

How Long Does It Take to Set Up a Malta Structure?

From planning to complete implementation usually takes 3–6 months. Setting up the Maltese company takes 2–4 weeks. The fiscal structuring and notifications in Germany take additional time.

What Ongoing Obligations Do I Have with a Malta Company?

You must file annual tax returns in Malta, prepare financial statements, and hold shareholder meetings. In Germany, additional information in your tax return and various notifications are required.

Can the Stuttgart Tax Office Object to My Malta Structure?

If your structure is EU-compliant and all reporting duties are fulfilled, there are no objections. The Stuttgart tax office is experienced with international structures. Professional advice from the start is vital.

What Happens in a Tax Audit with a Malta Structure?

Auditors will check the substance requirements: Is there real business activity in Malta? Are decisions made there? With proper documentation, this is not a problem.

Are My Managing Director Salaries Taxed Lower in Malta?

Director’s remuneration is usually subject to German payroll tax if you are resident in Germany. The Malta structure primarily optimizes company profits, not salaries.

Can I Integrate My Existing GmbH in Stuttgart into the Malta Structure?

Yes, that’s possible. Your existing GmbH can serve as a subsidiary of the Maltese holding. Alternatively, the Maltese company can acquire shares in your German GmbH.

What Are the Total Annual Costs of the Malta Structure?

Total annual costs are between €15,000 and €30,000. This covers tax advice in Germany and Malta, audits, corporate services, and ongoing compliance. Given adequate profits, this is highly cost-effective.

Do Other EU Countries Offer Tax Benefits Similar to Malta?

Countries such as Cyprus or Ireland also have attractive models. However, Malta is particularly efficient thanks to its tax credit system. The combination of low tax rates and full EU compliance is unique.

How Do I Find the Right Malta Specialist in Stuttgart?

Look for proven Malta expertise, references, and an established network in Malta. The advisor should be well-versed in both German and Maltese tax law. Ask for concrete examples of successful structuring.