Malta: Time limitation on applicability of grandfathering provision under transfer pricing rules
The applicability of the grandfathering provision is limited to three years.
The applicability of the grandfathering provision is limited to three years.
The Maltese transfer pricing rules provide for a grandfathering provision that disables the application of such rules for arrangements entered into before basis years commencing on or after 1 January 2024, provided that the arrangement is not materially altered.
The grandfathering provision initially applied without a time limitation; however, following a recent amendment to the Maltese transfer pricing rules, the applicability of the grandfathering provision is limited to three years. This means that arrangements entered into before the effective date of the Maltese transfer pricing rules and which are not materially altered would fall within the scope of the Maltese transfer pricing rules from basis years commencing on or after 1 January 2027.
Read a February 2024 report prepared by the KPMG member firm in Malta
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