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Malta: Updated guidance on Pillar Two rules, including delayed application of IIR and UTPR

Including guidance on filing obligations of constituent entities

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April 13, 2026

The Tax and Customs Administration published an updated Guidance Note clarifying the application of Malta’s global anti‑base erosion (GloBE) rules under Directive (EU) 2022/2523 (Pillar Two).

The guidance explains Malta’s election for delayed application of the income inclusion rule (IIR) and undertaxed profits rule (UTPR), limiting domestic transposition to the minimum required provisions.

The update also clarifies that Maltese constituent entities (CEs) are exempt from filing the GloBE information return (GIR), while Maltese ultimate parent entities (UPEs) must appoint a designated filing entity in another jurisdiction.

In line with a recently published legal notice, the update further explains that Maltese CEs are exempt from filing a notification that identifies the group entity that is filing the GIR and its location.


For more information, contact a KPMG tax professional in Malta:

John Ellul Sullivan | johnellulsullivan@kpmg.com.mt

Lisa Zarb Mizzi | lisazarbmizzi@kpmg.com.mt

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