Malta’s new Final Income Tax Without Imputation Regulations (FITWI)

By means of Legal Notice 188 of 2025, Malta introduced the “Final Income Tax Without Imputation Regulations, 2025”. These regulations establish an optional alternative tax regime for companies and other entities subject to tax in the same manner as companies in Malta. Under this regime, qualifying entities may elect to have their taxable income taxed at a fixed rate of 15%, with this 15% tax liability being treated as final for Malta tax purposes. Additionally, the Malta tax authorities have recently issued an election form for entities wishing to opt into FITWI.

The Speaker

Dr Ian Zahra joined Deloitte Malta in 2020 and currently forms part of the Tax team, focusing on domestic and international direct taxation. Ian has worked on a number of engagements dealing with the Malta direct tax consequences of local and foreign companies in various industries.

Ian is a lawyer by profession and, following his studies in law at the University of Malta, he graduated in international tax law from the University of Leiden in the Netherlands and worked as a teaching assistant at the International Tax Centre in Leiden. Ian has also been admitted to the Maltese bar.