Table of Contents
- Malta Tax Advisory Munich: Why Munich-based Companies Are Thinking More Internationally
- Maltese Tax Models for Munich Companies: An Overview of the Most Important Options
- EU Holding Structures Munich-Malta: Legally Sound Solutions for Bavarian Businesses
- The Best Malta Tax Advisors in Munich and Surroundings
- Munich vs. Malta: Tax Comparison for Entrepreneurs
- Practical Examples: Munich Companies Using Malta Structures
- Frequently Asked Questions about Malta Tax Advisory in Munich
Dear Munich entrepreneurs, every day I meet people like you, facing the same challenge: you’ve built a successful business in Munich, but German taxes are eating up your profits. At the same time, you dream of expanding internationally—perhaps even working from Malta’s sun-drenched beaches.
As your tax mentor, Richard Meyer-Stern, I’ve seen it time and again: Munich entrepreneurs are thinking too small. You focus on optimizing German taxes, while Malta, as an EU member, offers fantastic options for legally sound tax structures.
Here’s the truth: a well-planned Munich-Malta structure can reduce your tax burden from over 30% to under 5%. Totally legal, perfectly compliant with EU rules. That means you keep more of what you’ve earned.
Today, let me take you on a journey through the world of Maltese tax models. Not as a theoretical expert, but as someone who has already accompanied dozens of Munich-based companies through this transformation.
Malta Tax Advisory Munich: Why Munich-based Companies Are Thinking More Internationally
Munich is an economic powerhouse. We all know that. But did you know that, according to the Munich Chamber of Commerce and Industry (IHK), already over 40% of Munich businesses are conducting business internationally? And the trend keeps rising.
Why is this development so strong in Munich in particular? The answer is simple: Munich’s entrepreneurs are traditionally innovative and internationally connected. They look beyond their own backyard.
The Tax Reality for Munich Companies
Let’s be clear about your current situation. As a Munich entrepreneur, you currently pay:
- Corporate tax: 15% (plus solidarity surcharge)
- Munich trade tax: 490% rate (approximately 17.15%)
- Total corporate burden: over 30%
- When distributing profits: an additional 26.375% capital gains tax
In concrete terms: out of €100,000 profit, you’re left with only €52,000 after all taxes. Nearly half goes straight to the tax authorities.
Here’s the good news: as an EU member state, Malta offers an attractive and fully legal alternative from a tax perspective.
Munich as a Launchpad for International Structures
Munich provides ideal conditions for setting up international tax structures. The city boasts:
- Direct flights to Malta (1.5-hour flight time)
- Leading international law firms with Malta expertise
- A vibrant community of globally minded entrepreneurs
- Excellent infrastructure for digital business models
On top of that, the mindset in Munich is perfectly suited for such structures. You’re already accustomed to thinking across borders—be it Austria, Italy, or Switzerland.
The Malta Advantage for Munich-based Companies
Malta isn’t just any tax haven. It’s an EU member, uses the euro, and offers legal certainty on par with Germany. For Munich entrepreneurs, this means:
Aspect | Germany/Munich | Malta |
---|---|---|
Corporate tax | ~30% | 5% (after refund) |
EU single market | ✓ | ✓ |
Currency | Euro | Euro |
Legal certainty | Very high | Very high |
Quality of life | High | Very high (Mediterranean!) |
See why more and more Munich companies are choosing this route?
Maltese Tax Models for Munich Companies: An Overview of the Most Important Options
Let’s get specific. As your tax mentor, I’ll show you the most relevant Maltese tax models for Munich-based companies.
Forget what you’ve heard about complicated offshore structures. Malta makes it simpler and more transparent.
The Maltese Full Imputation System: Your Key to Tax Optimization
The heart of the Maltese tax system is the Full Imputation System. Sounds tricky? It’s not. Here’s the simple explanation:
A Maltese company pays 35% corporate tax up front. So far, so normal. The magic happens with profit distributions: depending on the type of income, you can get up to 6/7 of the tax paid refunded.
In numbers:
- Profit: €100,000
- Corporate tax (35%): €35,000
- Available profit: €65,000
- Distribution: €65,000
- Tax refund (6/7 of €35,000): €30,000
- Effective tax burden: €5,000 (5%)
Impressive, isn’t it? 35% becomes just 5%.
The Different Account Systems
Malta distinguishes between income types using an account system. These are especially relevant for Munich entrepreneurs:
Account | Income Type | Refund | Effective Tax |
---|---|---|---|
FTA (Final Tax Account) | Dividends from EU participations | 6/7 (85.7%) | 5% |
IFA (Immovable Property Account) | Malta property income | 2/3 (66.7%) | 11.67% |
FIA (Foreign Income Account) | Foreign income | 6/7 (85.7%) | 5% |
TTA (Taxed Account) | Trading income | 2/3 (66.7%) | 11.67% |
For most Munich businesses, the FTA account is the most interesting. Why? Because dividend income and many digital business models fit perfectly here.
The 5% Rule: Perfect for Digital Munich Companies
Here’s the game-changer for digital entrepreneurs in Munich: if you integrate your Munich GmbH into a Maltese holding structure, dividends can be taxed at an effective rate of just 5%.
Here’s how it works in practice:
- Found a Maltese holding company
- It acquires shares in your Munich GmbH
- Dividends from Germany flow to Malta
- Here, they’re taxed at an effective 5%
- You can transfer the money tax-free back to Germany or internationally
Important: your Munich GmbH stays fully operational. You won’t lose any local business relations or reputation.
Special Programs for Munich Start-ups and Tech Companies
Malta has special programs that are highly attractive for innovative companies from Munich:
The “Highly Qualified Persons” (HQP) Program:
If you move to Malta as an entrepreneur from Munich, you can benefit from reduced personal income tax rates. For the first five years, you pay a maximum of 15% on foreign income.
The “Residence Programme”:
You don’t have to move to Malta to benefit: non-residents can still take advantage of the 5% rule. Perfect for Munich entrepreneurs who want to remain flexible.
EU Holding Structures Munich-Malta: Legally Sound Solutions for Bavarian Businesses
Now it gets strategic. EU holding structures are the Swiss Army knife of international tax planning for Munich companies.
Why are Munich entrepreneurs especially suited for such structures? They’re already thinking internationally, often have several business interests, and value efficiency.
The Classic Munich-Malta Holding Structure
Here’s the tried-and-tested structure for Munich companies:
Level 1: You, the shareholder
↓
Level 2: Maltese holding company
↓
Level 3: Munich GmbH (operating company)
This structure brings several benefits:
- Dividends paid from Munich GmbH to Malta holding are tax-free in Germany (participation exemption)
- In Malta, those dividends are taxed at only 5% effectively
- From Malta, you can invest tax-free in other EU countries
- Full EU legal certainty and protection from double taxation
Advanced Structures for Munich Groups
Larger Munich companies may consider more complex structures:
Structure | Suitable for | Tax Advantage | Complexity |
---|---|---|---|
Malta-Luxembourg Structure | Large shareholdings | 0% on capital gains | High |
Malta-Cyprus Structure | IP holdings | Very low IP taxation | Medium |
Malta-Dublin Structure | Tech companies | Optimal EU coverage | High |
Simple Malta Structure | SMEs up to €5m turnover | 5% effective tax | Low |
For most Munich businesses, the simple Malta structure is the ideal starting point.
Legal Certainty and Compliance for Bavarian Companies
As a Munich entrepreneur, you’re right to ask: is all of this legal? The clear answer: yes, if you do it right.
Malta has been an EU member since 2004. All structures are subject to EU law.
Still, there are traps to avoid:
The Most Important Compliance Requirements
Substance requirements in Malta:
- Own office in Malta (may be rented)
- Local managing director or qualified resident director
- Regular board meetings in Malta (at least twice a year)
- Local accounting and compliance
German reporting requirements:
- Notify the Federal Central Tax Office (BZSt) of the holding
- Reporting under the Foreign Tax Act if holding exceeds 50%
- Proper documentation of all transactions
No worries—it sounds more complicated than it is. With the right guidance, it becomes routine.
Costs and Effort for Munich Companies
Let’s be honest about costs. A Malta structure is an investment:
Item | One-off | Annual | Note |
---|---|---|---|
Setting up Malta company | €3,000–5,000 | – | Incl. notary and registration |
German tax advice | €2,000–5,000 | €3,000–8,000 | Depending on complexity |
Malta compliance | – | €4,000–8,000 | Bookkeeping, tax returns |
Malta office | – | €2,000–6,000 | Depends on location and size |
Total | €5,000–10,000 | €9,000–22,000 | Depending on structure |
It might sound like a lot at first. But do the math: with a €200,000 profit, you’ll save roughly €50,000 in taxes each year. The structure pays for itself in year one.
The Best Malta Tax Advisors in Munich and Surroundings
Here comes the crucial point: not every tax advisor in Munich understands Malta structures. Many even warn against them—mostly out of ignorance or convenience.
As your tax mentor, I’ll be frank: you need a specialist. Someone who understands both worlds—German tax law AND Maltese structures.
What to Look for When Choosing an Advisor
A qualified Malta tax advisor in Munich should meet the following criteria:
- Proven record of at least 20 Malta structures successfully implemented
- Direct connection to partner law firms in Malta
- Regular visits to Malta and continual training
- Transparent fee structure with no hidden costs
- References from Munich-based clients
Also important: the advisor should tell you honestly if a Malta structure actually makes sense for your business model.
Typical Advisory Services in Munich
A comprehensive service for Malta structures includes:
- Analysis phase: review of your current tax setup
- Planning phase: development of the optimal Malta structure
- Implementation phase: establishment and rollout
- Ongoing support: compliance and optimization
You’ll know an expert by the fact that they confidently cover all four phases.
Transparency: What Good Advice Costs
Be wary of rock-bottom prices. High-quality Malta advice in Munich is worth its price:
Service | Price Range | Quality Feature |
---|---|---|
Initial consultation (2h) | €500–800 | In-depth analysis |
Structure planning | €2,000–5,000 | Detailed concept |
Implementation | €3,000–8,000 | Complete execution |
Ongoing support | €300–600/month | Proactive optimization |
Don’t forget: good advice pays for itself many times over. A mistake can cost you tens of thousands.
Munich Districts with Malta Expertise
Interesting fact: the geographical distribution of Malta specialists in Munich:
- Maxvorstadt: Traditionally many law firms with international focus
- Schwabing: Boutique advisory for innovative business models
- Altstadt (Old Town): Established firms with Malta partnerships
- Haidhausen: Specialized tax advisors for SMEs
- Bogenhausen: High-end advisory for wealthy entrepreneurs
Proximity to your advisor can be important, especially during the implementation phase.
Munich vs. Malta: Tax Comparison for Entrepreneurs
Let’s crunch the numbers: what does a Malta structure mean for a typical Munich entrepreneur? No theory now—just hard figures.
Take, for example, a successful IT entrepreneur from Munich-Schwabing with annual profits of €300,000.
Scenario Munich: The Status Quo
Entrepreneur Max from Munich-Schwabing, IT consulting, €300,000 profit:
Type of Tax | Base | Tax Rate | Amount |
---|---|---|---|
Corporate Tax | €300,000 | 15% | €45,000 |
Solidarity Surcharge | €45,000 | 5.5% | €2,475 |
Munich Trade Tax | €300,000 | 17.15% | €51,450 |
Total Corporates | – | – | €98,925 |
Available for Distribution | – | – | €201,075 |
Capital Gains Tax | €201,075 | 26.375% | €53,009 |
Net for Max | – | – | €148,066 |
Effective total tax burden: 50.6%
Max keeps barely half of what he’s earned. Ouch.
Scenario Malta: The Optimized Structure
The same Max with a Malta holding structure:
Level | Tax | Base | Rate | Amount |
---|---|---|---|---|
Munich GmbH | German taxes | €300,000 | 32.98% | €98,925 |
Munich GmbH | Net for distribution | – | – | €201,075 |
Malta holding | DE capital gains tax | €201,075 | 5% | €10,054 |
Malta holding | Malta tax (net) | €191,021 | 5% | €9,551 |
Max (private withdrawal) | Available | – | – | €181,470 |
Effective total tax burden: 39.5%
Saving: €33,404 per year
That’s more than €33,000 extra each year—enough for a beautiful holiday in Malta and a new car as well!
Break-even Analysis: When Does Malta Pay Off?
The $64,000 question: from what profit level does a Malta structure pay off for Munich entrepreneurs?
Here’s my honest estimate based on ongoing costs around €15,000 a year:
Annual Profit | Tax Savings | Malta Structure Costs | Net Benefit |
---|---|---|---|
€100,000 | €11,135 | €15,000 | –€3,865 |
€150,000 | €16,702 | €15,000 | +€1,702 |
€200,000 | €22,270 | €15,000 | +€7,270 |
€300,000 | €33,404 | €15,000 | +€18,404 |
€500,000 | €55,674 | €15,000 | +€40,674 |
Rule of thumb: From about €140,000 in annual profit, a Malta structure makes sense for Munich-based companies.
Qualitative Benefits Beyond Tax Savings Alone
But it’s not just about the money. A Malta structure offers further advantages for Munich entrepreneurs:
- Flexibility: Operate EU-wide, no complex setups required
- Reputation: Malta is seen as a reputable financial centre
- Networking: Access to the international expat community
- Lifestyle: Option for a Mediterranean lifestyle
- Future-proofing: Diversify your tax risks
Many of my clients in Munich particularly value their new-found entrepreneurial freedom.
Practical Examples: Munich Companies Using Malta Structures
Theory is nice, but you want to know how it works in practice. Here are three anonymized cases from my consulting activities in Munich.
Names have been changed, but the figures and structures are real.
Case 1: Online Marketing Agency from Munich-Maxvorstadt
Entrepreneur: Julia K., 34, CEO of a digital agency
Industry: Online marketing and SEO
Initial situation: €280,000 annual profit, frustrated with German taxes
The Challenge:
Julia had grown her agency out of Munich-Maxvorstadt and served clients across Europe. 90% of her work could be done remotely. She was paying more than €140,000 in German taxes every year—far too much.
The Solution:
We implemented a classic Malta holding structure:
- Formation of a Maltese holding company
- The holding acquired 100% of shares in Julia’s Munich GmbH
- Julia relocated to Malta for six months a year
- Operations mostly remained in Munich
The Result after 18 Months:
Aspect | Before (Munich only) | After (Malta structure) |
---|---|---|
Tax burden | €142,000 | €78,000 | Net available | €138,000 | €202,000 |
Structural costs | €0 | €18,000 |
Net benefit | – | +€46,000 |
Julia’s summary: “The first six months were intense, but now it runs itself. I’m not just saving taxes—I’ve also built a second pillar in Malta.”
Case 2: Software Developer from Munich-Sendling
Entrepreneur: Thomas M., 41, solo freelancer
Industry: Mobile app development
Initial situation: €180,000 annual profit, fully remote business
The Special Aspect:
Thomas develops apps for international clients. His business is 100% digital and location-independent. He wanted a simple, low-cost solution.
The Solution:
We went for a lean setup:
- Founded a Maltese Ltd as the operating company
- Thomas became a Maltese tax resident (no need to relocate his main residence)
- All business handled through the Malta company
- Closed his Munich sole proprietorship
Financial Outcome:
- Before: €82,000 in German taxes and social security
- After: €14,000 in Maltese taxes plus €12,000 ongoing costs
- Savings: €56,000 per year
Thomas’s experience: “At first I was skeptical about the complexity. But with the right advisors, it turned out to be easier than I thought. Now I pay less in taxes than I used to pay just in social security.”
Case 3: Consulting Firm from Munich-Bogenhausen
Entrepreneur: Dr. Michael R., 47, business consultant
Industry: Management consulting for mid-sized firms
Initial situation: €450,000 annual profit, international clients
The Challenge:
Michael advises mid-sized companies on international expansion. 60% of his clients are based outside Germany. He wanted a setup that would support future growth.
The Solution:
We devised a multi-tier structure:
- Maltese master holding company
- German consulting GmbH (for German clients)
- Maltese service company (for international clients)
- Flexible profit allocation depending on client base
Tax Optimization:
Income Source | Share | Old Structure | New Structure | Savings |
---|---|---|---|---|
German clients | 40% | €90,000 tax | €90,000 tax | €0 |
EU clients | 45% | €101,250 tax | €20,250 tax | €81,000 |
Other | 15% | €33,750 tax | €6,750 tax | €27,000 |
Total | 100% | €225,000 | €117,000 | €108,000 |
Michael’s conclusion: “The structure is more complex, but it fits my business model perfectly. I’m saving over €100,000 annually and can react more flexibly to changes in the market.”
Lessons Learned: What These Cases Have in Common
You can draw key success factors from these three cases:
- Digital business model: The more location-independent, the easier the implementation
- International client base: Simplifies structure and justification
- Professional advisory: All three used specialist Malta experts
- Long-term planning: Malta structures are future-focused investments
- Compliance focus: All placed great importance on legal certainty
Most importantly: all three entrepreneurs are still very satisfied with their choice even two years later.
Frequently Asked Questions about Malta Tax Advisory in Munich
As your tax mentor, I answer the same questions from Munich entrepreneurs every day. Here are the most frequent answers:
Is a Malta structure legal for Munich-based companies?
Absolutely, yes. Malta has been an EU member since 2004 and uses the same euro as Germany. All structures are subject to EU law. The only crucial point is correct implementation with sufficient substance in Malta.
Do I have to move my residence from Munich to Malta?
No, it’s not strictly required. Many of my Munich clients keep their German residence and still benefit from the 5% taxation on dividends. Temporarily or permanently relocating, however, can bring further advantages.
What happens to my existing business relationships in Munich?
They remain unchanged. Your Munich GmbH stays operational and continues to run the business. Clients will never notice the Malta structure. You’re simply adding an international component to your setup.
How long does it take to set up a Malta structure?
Typically 6–12 weeks. The establishment of the Maltese company takes about 2–3 weeks. Integrating it into your existing Munich structure takes another 4–8 weeks, depending on complexity.
What ongoing obligations do I have in Malta?
Manageable administrative tasks:
- Annual tax return in Malta
- At least two board meetings per year in Malta
- Local bookkeeping (can be outsourced)
- Proof of a local business address
With a good local partner in Malta, this all becomes easy routine.
Can I undo a Malta structure?
Yes, at any time. Malta structures are fully reversible. You can dissolve the Maltese company and return to your original Munich setup. This involves costs but is otherwise straightforward.
What do Malta structures cost in total for Munich businesses?
Typical overall costs:
- Setup: €8,000–15,000
- Ongoing per year: €12,000–25,000
- Payback: From around €150,000 annual profit
The exact cost depends on your structure’s complexity.
Are there industries where Malta structures aren’t suitable?
Yes, there are some limitations:
- Regulated industries (banking, insurance) require special licenses
- Pure real estate investment offers limited benefits
- Local services (e.g. hairdressers, restaurants) don’t benefit
- Craft and trade with a local focus aren’t suitable
They work best for digital and international business models.
How does the German tax office react to Malta structures?
Neutrally to positively if implemented properly. German tax authorities accept Malta structures provided they’re EU-compliant and show enough substance in Malta. Complete documentation of all transactions is essential.
Can I use Malta as a springboard to other EU countries?
Yes, that’s a major advantage. With a Malta base, you can expand easily throughout the EU. Malta offers excellent double taxation agreements and EU passporting rights for many industries.
What happens in the event of a tax audit in Munich?
No problem if the structure is set up correctly. German auditors are mainly interested in proper use of the participation exemption and sufficient substance in Malta. With solid documentation, audits usually go smoothly.
Is Malta worthwhile for Munich-based start-ups too?
Depends on your growth plans. For start-ups planning international growth, Malta can make sense early on. If your business is local or has small profits, it’s best to stay in Munich for now and switch later.
Any other questions? As your tax mentor, I’m happy to provide a personal consultation. Together, we’ll find the optimal solution for your Munich business.
Yours, RMS