MTCA establishes Malta’s Large Taxpayer Office

On 9 April 2025, the Malta Tax and Customs Administration (‘MTCA’) announced the establishment of the Large Taxpayer Office (‘LTO’) as part of its ongoing transformation strategy along with the issuance of the related policy document and frequently asked questions (‘FAQs’) outlining the LTO’s operation and eligibility criteria.

The establishment of the LTO underscores the crucial role that large taxpayers and high net-worth individuals (‘HNWIs’) play in the Maltese economy. In this respect, the LTO is designed to provide specialised and holistic services to qualifying taxpayers, serving as a one-stop-shop for all core tax services tailored to meet their specific needs.

Eligibility criteria

1. Companies - A taxpayer is considered a ‘Larger Taxpayer’ falling under the remit of the LTO if either of the following criteria is met:

a. First set of eligibility criteria:

• Annual turnover in any year of assessment (‘YA’) from 2020 to 2022 exceeds €20 million; and
• Employs 50 or more employees in any basis year from 2019 to 2022.

b. Second set of eligibility criteria:

• Annual turnover in any YA from 2020 to 2022 exceeds €20 million; and
• Value-added tax (‘VAT’) supplies criterion is met (total value of domestic supplies and exports reported for VAT purposes for YA 2022 was in excess of €10 million).

Moreover, the Commissioner for Tax and Customs (the ‘CfTC’) has the discretion to include taxpayers from specific sectors or segments within the LTO, even if the required criteria are not met.

2. HNWIs - A taxpayer is considered a HNWI falling under the remit of the LTO if any of the following criteria is met:

a. Shareholding criterion

• Direct 25% shareholding in a “subject company” being a company that has total assets in excess of €50 million reported in any year during the past 5 years; or
• 25% shareholding in a company that is directly or indirectly involved as shareholder (in whatever percentage) in a subject company.

b. Property transfer criterion

• Property acquisitions from year 2021 in excess of €3 million.

c. Income declared criterion

• Declared income in excess of €2 million in any of the following YAs: 2021, 2022 or 2023.
   

Organisational governance

The LTO is led by a director who reports directly to the CfTC. This office is responsible for managing income tax, VAT and customs issues for all qualifying taxpayers.

Services provided by the LTO

The LTO was structured to encompass, among other duties, the following operational functions:

• Taxpayer Service;
• Debt Management, Compliance and Payments;
• Verification, Audits and Objections; and
• Customs Unit

Organisational structure

The LTO has segmented its services into four sectors to adopt a proactive approach in managing taxpayer relationships as follows:

• Tourism / Wholesale and Retail;
• Gaming / Financial Services;
• Construction and Manufacturing; and
• HNWIs

This segmentation aims to provide dedicated support and oversight while fostering stronger relationships with large corporate taxpayers and HNWIs, based on a deep understanding of their industries and business sectors.

Each sector is assigned case managers who act as intermediaries between the large corporate taxpayers or HNWIs and other MTCA directorates to facilitate efficient communication and issue resolution.

Additionally, a separate audit and transfer pricing team are assigned to assess the propriety of qualifying taxpayers' tax positions.

Eligibility and change in status

Companies or individuals are not required to notify the CfTC if they meet the criteria for large taxpayer or HNWI status. Instead, the CfTC shall formally inform taxpayers when they qualify and shall also inform them if or when they no longer meet the criteria. Once classified as a large taxpayer or HNWI, the status is generally retained for the following three years and taxpayers are not required to re-verify or notify the CfTC that they continue to meet the established criteria.

Benefits of qualifying taxpayers

Qualifying taxpayers shall benefit from having their tax matters handled swiftly and efficiently by the LTO team. The LTO shall alleviate administrative burdens by tracking payment and compliance deadlines and providing personalised reminders of pending obligations.

Therefore, to maximise the benefits of the streamlined services, qualifying taxpayers must adhere to the deadlines for submitting all necessary documents and ensure prompt payment of taxes to avoid penalties and maintain good standing in line with international best practices. Compliance will ensure continued benefits derived from the streamlined services that are being offered to large taxpayers. Qualifying taxpayers shall also be expected to use modern compliance systems provided by the MTCA by filing returns and making payments electronically to ensure greater accuracy and efficiency.

The full policy document may be accessed here while the FAQs is accessible here.