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How to survive a transfer pricing audit in Malta

April 15, 2008

Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta

There is currently no specific tax legislation or specific tax rules that regulate transfer pricing in Malta. To date there are no pending proposals in parliament with respect to enacting specific legislation in respect of transfer pricing. Although no transfer pricing legislation is available, the Maltese tax authorities would typically still consider it desirable that transactions between residents and non-residents broadly adhere to the arm’s length principle, that is, prices that would have been concluded between independent enterprises. However no rules or guidance are available on the manner in which an arm’s length price is to be established.




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