Malta Transfer Pricing Documentation Requirements
Malta introduced formal transfer pricing rules applying to basis years beginning on or after 1 January 2024. In-scope entities, determined by the aggregate value of their cross-border arrangements with associated enterprises, must prepare a Master File and a Local File documenting those arrangements.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Entities within the scope of the Maltese Transfer Pricing Rules (by aggregate cross-border arrangement value) | By the return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | EN / MT | Not captured |
Local File Required | Same scope test as the Master File | By the return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | EN / MT | Not captured |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
Malta’s Transfer Pricing Rules apply to basis years beginning on or after 1 January 2024. Whether an entity is within scope is determined by the aggregate arm’s length value of its cross-border arrangements with associated enterprises, with entities below the de minimis level falling outside the rules. An in-scope entity must prepare a Master File and a Local File documenting those arrangements, prepared by the return filing date and held available for the tax authority.
Distinctive features of the Maltese regime
The defining feature of the Maltese regime is its recency. The formal documentation requirement is new, applying only from the 2024 basis year, so it represents a shift from a position in which Malta had no codified transfer pricing documentation rules to one aligned with the OECD Master File and Local File structure. The scope test turns on the aggregate value of cross-border arrangements with associated enterprises rather than on a turnover or balance-sheet figure, which focuses the obligation on the size of the related-party dealings themselves. The documentation may be prepared in English or Maltese.
Benchmarking and comparables
The Maltese rules align with the OECD approach to documentation. Detailed local practice on the choice between local and foreign comparables, on single-year versus multi-year testing, and on the frequency of fresh searches is developing as the rules take effect, and an in-scope entity is expected to support its arrangements with a comparability analysis consistent with the OECD framework.
Frequently asked questions
When did Malta's transfer pricing documentation rules take effect?
They apply to basis years beginning on or after 1 January 2024, marking Malta's move from no codified documentation rules to a Master File and Local File requirement aligned with the OECD structure.
What determines whether a Maltese entity is in scope?
The aggregate arm's length value of its cross-border arrangements with associated enterprises. Entities below the de minimis level fall outside the rules.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.