Service

International Tax Advisory

DW&P advises international entrepreneurs and businesses on all aspects of international taxation. From exit taxation planning to transfer pricing documentation and double tax treaty optimization – our team combines European tax law expertise with local Malta knowledge.

International Tax Advisory operates in the international tax law segment, serving entrepreneurs and companies with cross-border tax planning.

International Tax Advisory: Advisory Areas

Exit Taxation

  • § 6 AStG: Exit taxation on shareholdings ≥1%
  • Deferral: In EU/EEA states (including Malta)
  • Extended limited tax liability: 10-year rule
  • Deemed disposal: Valuation issues
  • Prevention: Structuring before emigration

Transfer Pricing

  • Arm's length principle: OECD-compliant pricing
  • Documentation: Transfer pricing studies
  • Intercompany agreements: License, service, loan
  • Advance Pricing Agreements: APA negotiations

Double Tax Treaties

  • Malta DTA network: 70+ treaties
  • DTA DE-MT: Avoidance of double taxation
  • Withholding taxes: Reduction/exemption
  • Treaty shopping: Prevention & compliance

Structuring

  • Holding structures: Malta, Luxembourg
  • Substance requirements: Office, employees, decisions
  • Profit repatriation: Tax-efficient distribution
  • Exit strategies: Sale of shares vs. assets