Malta: Exemption for local group members from filing GIR and related notifications
Local group entities exempt from filing the GloBE information return (GIR) under Pillar Two
A legislative amendment published on February 20, 2026, provides that Maltese constituent entities (CEs) are exempt from filing the GloBE information return (GIR) and making related notifications.
The amendments are consistent with Article 50 of the EU Minimum Tax Directive, which permits EU member states to defer the application of the income inclusion rule (IIR) and the undertaxed payments rule (UTPR) until December 31, 2029, provided that a maximum of 12 ultimate parent entities (UPEs) are based in that EU member state. Estonia, Latvia, Lithuania, Malta, and Slovakia have utilized this option, with Slovakia already implementing a domestic minimum top-up tax (DMTT) for fiscal years starting on or after December 31, 2023.
According to Article 50(2) of the EU Minimum Tax Directive, groups headquartered in EU countries that have chosen the deferral must nominate a designated filing entity in another jurisdiction where a qualifying competent authority agreement (DAC9 or GIR MCAA) is in effect. This designated filing entity will be responsible for filing the GIR. Constituent entities located in the deferring member state must provide the designated filing entity with the necessary information and are exempt from the filing obligations outlined in Article 44(2) of the EU Minimum Tax Directive.
Read a March 2026 report prepared by KPMG’s EU Tax Centre