1267664884

The Malta Transfer Pricing Rules: A Walkthrough

Location EY Malta, Regional Business Centre, Achille Ferries Street, Msida, Malta, MT

Time 09:15 - 11:15

Introduction

On 18 November 2022 the Minister for Finance and Employment issued Legal Notice 284 of 2022 (‘LN 284/22’), which provides for the formal introduction of specific transfer pricing rules in Malta  (‘TP Rules’). The TP Rules will apply as from any financial year commencing on or after 1 January 2024 and vis-à-vis any arrangement entered into on or after the said date and any other arrangement which, albeit was entered into before the said date, is materially altered on or after that date.

The TP Rules can be split into three parts. The core transfer pricing rules are provided for in the first part, whereas in the second and third parts the TP Rules provide for the introduction of mechanisms related to formal unilateral transfer pricing rulings and advance pricing agreements respectively.

Who Should Attend?

The session is aimed at CFOs working for multinational enterprises, tax specialists, tax practitioners and tax advisors.  

Session Outline

The session will be split in three parts. In the first part, we will go through the various transfer-pricing related rules and principles contemplated in the existing provisions. In the second part, we will cover the core transfer pricing rules contemplated in the TP Rules, with particular focus on the relevant definitions, thresholds and exclusions and, in the process, the identification of the circumstances where the TP Rules will apply. Lastly, we will address the requirements and process concerning the formal unilateral transfer pricing rulings and advance pricing agreements contemplated in the second and third parts of the TP Rules respectively.

CPE Accreditation

This workshop is eligible for 2 Core CPE hours. 

Fee

Registration fee for this workshop is €55.

Speakers

Silvio Camilleri | Senior Manager | Business Tax Advisory 

Silvio Camilleri is a Senior Manager within EY Malta’s Business Tax Advisory department. Silvio is a CPA by profession and joined EY Malta in 2012 after graduating from the University of Malta. Initially, Silvio worked within the Business Tax Compliance department, wherein he has assisted both corporate clients and individual clients in fulfilling their annual tax compliance obligations in Malta. After two years, Silvio moved on to the tax advisory arm of the firm and has since been advising multinational and local clients on direct tax issues from both a domestic and an international perspective. Silvio also lectures the Maltese tax modules for ACCA and has successfully sat for the Advanced Diploma in International Taxation at the Chartered Institute of Taxation.  

Kurt Cuschieri | Manager | EY Malta’s Tax Department 

Kurt Cuschieri is a Manager within EY Malta’s Tax Department. Kurt is a certified public accountant and joined EY Malta in 2013 after obtaining the Bachelor of Accountancy (Hons.) from the University of Malta. During his time at EY, he has worked in various sub-service lines within the Tax Department. Kurt is currently involved in providing tax advisory services to both local and multinational clients operating in various sectors on a number of matters including setting up of operations in Malta, cross border transactions and impact arising from tax legislation changes.