Malta has amended its EU Pillar Two regulations to exempt local constituent entities from filing top-up tax returns and notifying other group entities, applying to multinational and large domestic groups for financial years starting 31 December 2023.
Malta’s government has issued amendments to the European Union Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups, Subsidiary Legislation 123.212, under Legal Notice 48 of 2026, published on 20 February 2026.
The revisions exempt constituent entities located in Malta from submitting a top-up tax information return to the Commissioner for Tax and Customs. Where relevant, these entities are also not required to notify the Commissioner of the identity or jurisdiction of any other constituent entity filing the return.
These changes apply to qualifying multinational enterprise groups and large-scale domestic groups for financial years starting 31 December 2023 (financial year 2024).
The amendments, issued by the Minister for Finance, update existing rules under the Income Tax Act to clarify compliance obligations and reduce administrative requirements for major domestic and international corporate groups, ensuring alignment with EU minimum tax standards.
