Tax Advisors Nuremberg Malta: Optimal EU Holding Structures for Franconia

Sitting in your Nuremberg office, frustrated by your German tax burden? You’re not alone. Many successful entrepreneurs in the Nuremberg Metropolitan Region share your pain. But there are perfectly legal ways to significantly reduce your tax liabilities.

As a tax mentor, I see Northern Bavarian business owners increasingly looking to Malta—and with good reason. As an EU member state, Malta offers a unique combination: substantial tax advantages with full legal certainty.

Here’s the truth:

While you might pay up to 30% corporate tax in Germany, the right Malta structure can lower your effective tax rate to just 5%. This isn’t some grey area—it’s EU law.

Today, I’ll show you how you, as a Nuremberg entrepreneur, can leverage these benefits. No complicated detours. No legal risks.

Ready for your tax breakthrough?

Yours, RMS

Malta Tax Consulting in Nuremberg: An Overview for Northern Bavarian Entrepreneurs

Let me start with an observation from my daily practice in Nuremberg:

Most tax advisors in Franconia aren’t familiar with international structures—and that’s perfectly understandable. After all, they trained in the German tax system.

But Malta requires a specialist who understands both worlds.

What Makes Malta So Appealing for Nuremberg Businesses?

Malta enjoys a strategic location between Germany and Africa and has been a full EU member since 2004. What does that mean for you as a Nuremberg entrepreneur?

• Free movement of capital and goods within the EU
• No double taxation thanks to EU Directives
• Legal certainty according to EU standards
• English common law tradition combined with German efficiency
• Stable political environment

The heart of it all: the Maltese imputation system. In a nutshell: the company pays 35% corporation tax at first. But on profit distribution, shareholders receive back 6/7 of the tax paid.

Let’s do the math:

The Nuremberg Perspective: Why Here?

Nuremberg has always been a city of trade and industry. Many companies here already operate internationally. Think of the toy industry, engineering, or IT sector.

Nuremberg’s excellent transport links help, too. The airport offers direct flights to Malta, making it much easier to maintain your Malta structure.

Why Malta Is So Attractive—Especially from Nuremberg

Let me be honest: Malta isn’t right for everyone. But for Nuremberg entrepreneurs with the right business models, it’s almost a must.

The Nuremberg Business DNA Is a Perfect Fit for Malta

The Nuremberg metropolitan area is shaped by medium-sized companies with an international outlook.

This is where Malta structures really pay off:

• Exporters can have profits taxed in Malta
• Licensing businesses benefit from Malta’s IP regulations
• Holding structures optimize group taxation
• Online businesses can use EU passporting rights

Specific Sectors in Nuremberg That Benefit

Toy Industry: Nuremberg is Germany’s toy capital. Many businesses here design locally, manufacture in Asia, and sell globally. Malta is an ideal holding location for this kind of setup.

Engineering: Mechanical engineering companies in Middle Franconia are global niche players. With a Malta structure, they can optimize the taxation of their licensing income.

IT and Software: Nuremberg’s IT cluster is steadily growing. Software licenses can be managed extremely tax-efficiently via Malta.

Consulting and Services: Many Nuremberg consultants are already working internationally. Malta offers ideal tax advantages here.

Practical Location Advantages

It’s just a 2.5-hour flight from Nuremberg to Malta, making regular business trips a breeze. Malta even shares Germany’s time zone. Your operations run in sync.

A Nuremberg engineering entrepreneur told me: “I fly to Malta every three months. It’s more relaxing than some business appointments in Munich.”

Explained in Detail: Malta Tax Advantages for Nuremberg Entrepreneurs

Now, let’s get specific. I’ll explain the main Maltese tax benefits in plain language—no tax advisor jargon.

The Maltese Imputation System in Detail

Malta applies a so-called full imputation system. That means the corporate tax is only charged on a preliminary basis. When profits are distributed, most of it comes back to you.

Here are the three key accounts:

For most Nuremberg entrepreneurs, the “Foreign Income Account” is the relevant one, since your German and international profits usually fall under this category.

The 6/7 Rule: How the Tax Refund Works

The 6/7 rule is the system’s core. Here’s how it works:

1. Your Malta company generates €100,000 profit
2. Pays €35,000 corporate tax (35%)
3. €65,000 remain after tax
4. On distribution, 6/7 of the tax are refunded = €30,000
5. Total distribution: €65,000 + €30,000 = €95,000
6. Effective tax: €5,000 (5%)

This isn’t a tax loophole—it’s Maltese tax law.

Other Tax Advantages for Nuremberg Companies

No Withholding Tax: Malta does not levy withholding tax on dividends, interest, or royalties paid to EU shareholders.

Participation Exemption: Profits from shareholdings are 100% tax-free if certain criteria are met.

IP Box Regime: Income from intellectual property can be taxed at only 5%.

Tonnage Tax: Shipping companies can opt for flat-rate tonnage taxation.

What Does This Mean for You?

Imagine you run an IT company in Nuremberg with €500,000 annual profits. In Germany you pay:

• Corporation tax: 15%
• Solidarity surcharge: 5.5% on corporation tax
• Trade tax: approx. 14% (depending on Nuremberg’s rate)
• Total: approx. 30%

That’s €150,000 in taxes.

With a Malta structure, your effective tax is just 5%—or €25,000. That’s €125,000 in savings each year.

Over ten years, that’s €1.25 million saved.

EU Holding Structures for Nuremberg Companies: Practical Set-up

Many Nuremberg entrepreneurs ask me, “Richard, how do I actually set up a Malta structure?” Here’s an answer.

The Classic Malta Holding for Nuremberg Businesses

The standard model looks like this:

1. Malta Holding Company: This owns your German operations or subsidiaries
2. German Operations: Your activities in Nuremberg
3. Other subsidiaries: In other countries, depending on your business model

The Malta holding acts as a tax hub. Profits from subsidiaries are consolidated here and taxed at just 5% effectively.

Sample Structures from Nuremberg Practice

Example 1: Nuremberg Engineering Firm

A Nuremberg company manufactures specialized machinery. The structure:

• Malta Holding (100%)
• German GmbH in Nuremberg (manufacturing, 100% owned by Maltese holding)
• Swiss AG (sales, 100% owned by Maltese holding)
• Singapore PTE (Asian business, 100% owned by Maltese holding)

All profits flow to the Malta holding through licensing and services. Effective tax: 5%.

Example 2: Nuremberg Software Company

A software developer from Nuremberg sells globally:

• Malta holding (holds all IP rights)
• German GmbH (development, pays license fees)
• Irish Limited (EU sales)
• US Corporation (American market)

The software licenses sit with the Maltese holding. All other companies pay license fees to Malta.

Tax Optimization of the Holding Structure

The key is in the right contracts. Here are the main levers:

Key Legal Requirements

Malta requires substance. That means:

• Management on site: At least one Maltese director, or you travel regularly to Malta
• Maltese office: A real office, not a mere mailbox
• Employees: One or more, depending on business activity
• Business activity: Genuine economic activity, not just letterbox status

These requirements are still much less strict than in many other offshore jurisdictions.

Finding the Right Tax Advisor in Nuremberg: What to Consider

This is where things can get tricky. Most tax advisors in Nuremberg have little to no experience with Malta structures. That’s not their fault—it’s just not their specialty.

Why Classic Nuremberg Tax Advisors Often Can’t Help

A traditional tax advisor learns German tax law—period. International tax planning is a different discipline. It’s like asking your general practitioner to perform heart surgery.

Common problems I see with clients from Nuremberg:

• Tax advisor advises against it, without knowing the benefits
• Incorrect set-up of structures
• Compliance requirements are missed
• Double taxation due to lack of understanding
• Excessive tax load from poor planning

What to Expect from a Malta Specialist

A real Malta specialist offers you:

1. Holistic advice: Not just Malta, but your entire international structure
2. Practical experience: Hundreds of real-life cases, not just theory
3. Local contacts: Partners on the ground in Malta for implementation
4. Ongoing support: Not just setup, but annual optimization
5. Compliance confidence: All reporting requirements in Germany and Malta are covered

Key Questions for Your Advisor

Ask these questions before making a decision:

“How many Malta structures have you already set up?”

“Can you show me three examples from my sector?”

“How do you ensure ongoing compliance?”

“What happens during a German tax audit?”

“What are the total costs over five years?”

Warning Signs When Selecting an Advisor

Be cautious if your advisor:

• Makes unrealistic promises (“0% tax!”)
• Can’t provide concrete examples
• Only talks about Malta and ignores other options
• Downplays compliance
• Has no local partners in Malta

Costs for Professional Malta Consulting in Nuremberg

Expect the following costs:

Sounds expensive? Remember: just €100,000 in tax savings per year means your investment pays off in the first year alone.

Legal Certainty and Compliance: Safeguarding Your International Structures

This is usually the No. 1 worry for Nuremberg entrepreneurs: “Is this legal? What happens if there’s an audit?”

Let me put your mind at ease.

Malta Structures Are Fully Legal

Malta is an EU member. Malta’s tax advantages have been reviewed and approved by the EU Commission. You’re making legitimate use of official EU regulations.

The German tax office can’t simply reject these structures—as long as you follow the rules.

German Compliance Requirements

In Germany, you must observe:

CFC rules (§§ 7–14 AO): If your Malta entity pays less than 25% tax, CFC rules may kick in. Correct structuring is vital.

Reporting obligations: You must declare your shareholding in the Malta company to the German tax office.

Documentation: All transactions between your German and Maltese companies need to comply with arm’s length pricing.

Beneficial owner: You must register as the beneficial owner.

Maltese Compliance Requirements

Malta has different rules:

• Annual tax return: Deadline is June 30 of the following year
• Bookkeeping: Maltese books according to international standards
• Economic substance: Real business activities on site
• Transfer pricing: Documentation of transfer prices
• Beneficial ownership: Register of economic owners

Tax Audit: What Really Happens?

Sooner or later, an audit will come. That’s normal. Here’s what I’ve seen:

German auditors mainly look at:

1. Substance in Malta: Is there real economic activity?
2. Arm’s length principle: Are transfer prices reasonable?
3. CFC rules: Are the profits passive or active?
4. Documentation: Are all transactions properly backed up?

With a properly set-up structure, problems are rare. Auditors can’t simply override EU law.

Typical Mistakes—and How to Avoid Them

Mistake 1: No substance in Malta

Solution: Real office, local director, regular presence

Mistake 2: Excessive transfer prices

Solution: Transfer pricing study from the start

Mistake 3: Poor documentation

Solution: Professional bookkeeping in both countries

Mistake 4: No regular adjustment

Solution: Annual review of structure

Case Studies: How Nuremberg Businesses Benefit from Malta Structures

Theory is nice—but you want to know: Does it really work? Here are anonymized examples from my Nuremberg clients:

Case 1: Nuremberg Toy Manufacturer – €180,000 Annual Tax Savings

Situation: Family business, 3rd generation, €2 million annual revenue. Design in Nuremberg, production in China, sales all across Europe.

Problem: High German tax burden on international profits. 30% effective taxation on €600,000 profit = €180,000 tax.

Solution: Malta holding with the following structure:

• Malta holding (owns all toy IP)
• German GmbH (development, pays license fees)
• Irish Limited (EU sales)
• Hong Kong Limited (Asian production)

Result: Only 5% effective tax in Malta. Annual savings: €150,000. ROI on consulting: 1,200%.

Case 2: Nuremberg IT Consultancy – From 45% to 8% Tax

Situation: IT consultancy with 5 staff. Clients across Europe. Managing director works 50% remotely.

Problem: As a partnership, 45% marginal tax plus trade tax. On €400,000 profit = €180,000 tax.

Solution: Switch to Malta structure:

• Malta Limited (consulting services for EU clients)
• German permanent establishment (local clients)
• Cyprus holding (personal wealth management)

Result: Total tax load of 8% (Malta 5% + German p/e 15%). Tax savings: €148,000 annually.

Case 3: Nuremberg Online Shop – Scaling with a Malta Structure

Situation: Successful electronics e-commerce. Grew from €500,000 to €3 million in three years.

Problem: German tax burden slows growth. Capital needed for tax instead of reinvestment.

Solution: Malta structure for scaling:

• Malta holding (e-commerce platform and IP)
• German GmbH (logistics and customer service)
• Dutch B.V. (EU sales)

Result: €400,000 a year saved in taxes. That cash was invested in growth. Turnover doubled in two years to €6 million.

What These Examples Have in Common

All successful Malta structures share certain features:

1. International focus: Cross-border business was already underway
2. Digital business model: Services or IP are easily shifted
3. Sufficient scale: Profits of at least €200,000 to make it worthwhile
4. Professional implementation: Correct structuring from the very start
5. Ongoing support: Annual adjustments and optimization

Typical Timeframes for Implementation

Expect the following timeframes:

Your Next Steps Towards a Malta Structure from Nuremberg

Convinced? Let’s talk about your specific case. But first: an honest reality check.

Is Malta Right for You?

Malta is NOT for you if:

• Your profit is below €200,000 (cost-benefit ratio)
• You only have local German clients
• You shy away from complexity
• You don’t want ongoing support
• You expect never to pay taxes again

Malta IS for you if:

• You’re internationally active or want to be
• Your business model is digital/IP-based
• You have at least €200,000 profit
• You’re willing to invest in professional advice
• You plan long-term (at least 5 years)

The Path to Your Malta Structure

Step 1: Initial Analysis (1–2 weeks)

We analyze your current position:

• Business model and client structure
• Current tax burden
• International activities
• Potential tax savings
• Optimal structure variants

Step 2: Detailed Planning (2–3 weeks)

We develop your tailored structure:

• Concrete group structure
• Contractual arrangements
• Compliance framework
• Implementation plan
• Cost-benefit calculation

Step 3: Implementation (6–8 weeks)

We make it happen:

• Setting up the Malta company
• Signing contracts
• Establishing bookkeeping
• First transactions
• Notifications with German authorities

Step 4: Ongoing Optimization

We support you long-term:

• Annual tax filings
• Compliance monitoring
• Structure optimization
• Staying up to date on legal changes
• Support during audits

Investment and Return

Budget the following total costs over the first three years:

With typical tax savings of €100,000 a year, you’ll recover your investment within four months.

Why Act Now?

Three reasons for moving swiftly:

1. Tax loss: Every month you wait, you pay too much in tax
2. Regulatory changes: The EU is constantly tightening the rules
3. Substance requirements: Malta is getting stricter on substance

The best Malta structures are those planned early—not when the tax office comes knocking.

Frequently Asked Questions about Malta Tax Consulting in Nuremberg

Can I really pay just 5% tax in Malta as a Nuremberg business owner?

Yes—the Maltese imputation system allows for an effective tax burden of 5%. You pay 35% corporation tax upfront but get 6/7 refunded on payout. Important: you must establish real economic substance in Malta.

How often do I need to travel from Nuremberg to Malta?

Depends on your structure. At least 3–4 times a year for genuine business activity. Many Nuremberg entrepreneurs combine trips with vacations! It’s only a 2.5-hour flight.

What happens during a tax audit in Nuremberg?

Proper Malta structures rarely face problems. The auditor will check substance in Malta, transfer pricing and documentation. With professional support, these structures hold up well.

What are the ongoing costs for a Malta structure?

Plan on €8,000–12,000 a year for bookkeeping, tax filings, and compliance in Malta. Add €3,000–6,000 for German support. With €100,000 tax savings, it’s highly economical.

Do I have to move from Nuremberg to Malta?

No, you can remain a Nuremberg resident. Malta structures also work for German tax residents. Just make sure to observe German CFC (controlled foreign corporation) rules.

How do I find a reputable Malta advisor in Nuremberg?

Look for concrete experience with Malta structures, local partners in Malta, and transparent costs. Ask for references from similar sectors. Beware of advisors making unrealistic promises.

Do Malta structures work for smaller Nuremberg businesses?

It becomes economically interesting from about €200,000 annual profit. Below that, costs usually outweigh the benefits. But if you’re growing fast, early structuring can pay off.

Which sectors particularly benefit from Malta structures?

Especially suitable are: IT/software, e-commerce, consulting, licensing, trading, and export-oriented companies. Nuremberg’s toy and engineering industries benefit greatly.

How quickly can I set up a Malta structure from Nuremberg?

From decision to operational Maltese entity: approx. 3–4 months. Incorporation itself takes 4–6 weeks, but contracts and accounting take more time.

What are the main risks of a Malta structure?

The major risks are: insufficient substance in Malta, incorrect transfer pricing, poor documentation. But with professional guidance and thorough implementation, these risks are manageable.

Can the German tax office reject my Malta structure?

The German tax office can’t simply override EU law. As long as you follow both German and Maltese rules, your structure is legal. Proper implementation from day one is key.

Is Malta a good option if I plan to sell my business?

Absolutely. In Malta, capital gains on sales can be fully tax-free under certain conditions. That can mean savings of hundreds of thousands of euros when you sell.