Earlier this month, Legal Notice 48 of 2026 was published, providing a status update regarding the filing requirements applicable to constituent entities located in Malta falling within the scope of the EU Minimum Tax Directive.
This Legal Notice effectively removes the obligation previously imposed on Maltese constituent entities to submit a notification identifying the entity responsible for filing the Top-up Tax Information Return, as well as the jurisdiction in which such entity is located.
All other provisions introduced under the original rules (Legal Notice 32 of 2024) remain applicable. These include, among others, the exemption granted to Maltese constituent entities from filing the Top-up Tax Information Return locally, as well as the deferred application of the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR).
Notwithstanding the above, constituent entities established in Malta are still required to provide the designated filing entity with all information necessary to enable compliance with the requirements of the EU Minimum Tax Directive.
For further information, kindly contact our tax team on directtaxation@bdo.com.mt.