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SIF – Specialised Investment Fund A specialised investment fund based in Luxembourg is in principle exempt from income tax. The subscription tax is 0.01% per annum. The basis for calculating the subscription tax is the total net asset value of the specialised fund. The company is liable to a one-off capital tax of €1,250 payable on incorporation. SICAR – company with risk capital investments (Authorised capital of at least EUR 1mn) Annual capital turnover tax of EUR 1,250. Corporate tax 29.63%. There are no restrictions under double tax treaties. Profit distributions are not subject to source tax. Income from securities is exempt from tax. Proceeds from the liquidation of a company are not taxed (for non-resident participants)
Luxembourg does not tax profits generated by offshore bank accounts. An offshore Luxembourg bank account is a guaranteed means of capital protection. All information in offshore bank accounts in Luxembourg is considered confidential and may not be disclosed without the express authorisation of the bank account holder.
Luxembourg offers unique business opportunities due to its stable economy, favourable tax system, strategic location, quality financial services and high standard of living. These factors make it an attractive location for international investors and entrepreneurs seeking to expand their operations or enter the European market.
However, business success in Luxembourg requires careful planning and understanding of the local environment. This includes choosing the best legal form for the company, strategic planning, complying with regulatory requirements and proactively engaging with local partners and regulators.
Overall, Luxembourg offers a favourable environment for business development, backed by a highly skilled workforce, an innovative economy and a stable legal system.

In Malta, it is possible to incorporate a closed and a public limited company. The minimum share capital of a public company is €46600 and €1200 for a private company. At the time of incorporation, at least 25 per cent of the capital of a public limited company and 20 per cent of the capital of a private limited company must be paid up.
Taxation
Profits earned by a resident company, whether in Malta or abroad, are subject to income tax at the rate of 35%. However, Malta does not impose tax on dividends, interest and royalties remitted abroad (no withholding tax) and Malta has no transfer pricing or thin capitalisation rules.
(transfer pricing-the sale of goods or services to interdependent persons at intracompany, non-market prices. They allow the redistribution of the total profits of a group of persons in favour of persons in lower tax states. This is the simplest and most common scheme of international tax planning aimed at minimising taxes paid;
thin capitalisation – when the company’s activities are financed by borrowed funds).
Value Added Tax is levied on the sale of goods, works and services in Malta. The VAT rate on the island is 18%. Some goods are subject to preferential rates of 5% (e.g. printed publications, hotel services) and 0% (medicines and foodstuffs). There is no property tax and there is no turnover tax on the transfer of shares in companies owned by non-residents. Malta also has no exchange control legislation and a Maltese company can conduct its economic activities in any currency in the world.

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