Now it’s time to talk about double and triple structures – what they are, and why they might be a smart move for your business.

Here’s the gist: a double structure means you’ve got two Maltese (or international) companies working together – typically a holding company (HoldCo) and an operating company (OpCo). The operating company runs the show – doing business, making sales, hiring staff, signing contracts, while the holding company quietly owns the big stuff – shares, intellectual property, cash reserves, maybe real estate. Think of it as the backstage manager that owns the stage but doesn’t perform in the play.

Why bother with this setup? Well, for a few valid reasons:

Risk Management – if things go sideways with the OpCo (say a legal issue or debt), the HoldCo and its assets are generally shielded.
Asset Protection – key assets like trademarks, patents, or your secret sauce stay safe under the HoldCo, even if something happens to the trading side. The assets/monies can also remain “parked” in the HoldCo and defer the payments of any dividends in the foreign tax jurisdiction of residence of the ultimate beneficial owner.
Flexibility & Growth – if you are an expat resident in Malta you can expand abroad by holding your Malta OpCo from, say, a Cyprus or UK HoldCo, each giving access to different treaty networks and corporate reputations whilst remaining tax compliant in Malta.
Tax Benefits – depending on how you set it up (say, using Malta’s full imputation system or combining with foreign entities like a Cyprus or UK HoldCo), you can access attractive effective tax rates – sometimes as low as 5%.

What about a triple structure? That’s just one step further. Add another layer – maybe an international holding company (like one in the UK) sitting above a Maltese HoldCo, which in turn owns your Maltese OpCo. This extra level might sound fancy, but it’s often used for extra tax neutrality, investor protection, or aligning with the residence of the beneficial owner. This structure is recommended when the ultimate beneficial owner is resident (but not domiciled) in Malta.

So, which structure fits you?

A double structure with two Maltese companies: MT OpCo and MT HoldCo

This structure will enable tax consolidation and paying directly a corporate tax of 5% on all the taxable profits earned by the same.

This setup involves two Maltese entities – MT OpCo and MT HoldCo. When both are part of a fiscal unit under Malta’s Consolidated Group (Income Tax) Rules, they are treated as a single taxpayer.

 A double structure with two Maltese companies: MT OpCo and MT HoldCo

A double Maltese structure with fiscal unit: MT OpCo & MT Private Foundation

This structure is recommended in specific planning scenarios, particularly where asset protection, estate planning, or long-term wealth structuring are key objectives.

STRUCTURE: OpCo (business) owned by Maltese Private Foundation

Ideal for:	Entrepreneurs, HNWIs, family offices
Tax Strategy:	Fiscal unit, effective tax rate 5%
Purpose:	Combine business operations with long-term planning
Avoid if:	Simplicity, outside investors
Estate Planning:	No inheritance or wealth tax in Malta; foundation can survive generations
Asset Protection:	Foundation is a separate legal person, insulating assets from personal risks
Control vs. Ownership:	Separation of legal ownership (foundation) from control (via Supervisory Council/BoM)
Privacy:	Private foundations are not publicly listed like companies
Philanthropy or Purpose-Oriented Planning:	Foundation can define specific goals beyond pure profit

A double structure with an MT company owned by a foreign holding entity

In the event that the shareholder is an expatriate moving to Malta becoming resident therein, it is recommended to set up a tax neutral foreign holding entity to act as the shareholder of the MT OpCo in order to benefit from the latter income tax refund.

Common examples include:

a double structure with an MT OpCo owned by a Cyprus holding company (Cyprus HoldCo)
a double structure with an MT OpCo owned by a UK holding company (UK HoldCo)

In the earlier examples, the fiscal unit mechanism was mentioned. However, this option is only available when both companies are tax-resident in Malta. In cases involving Cyprus or UK holding structures, the fiscal consolidation regime does not apply. Instead, Malta’s tax refund system becomes relevant.

 A double structure with an MT company owned by a foreign holding entity

Comparison of Double Structures Involving MT OpCo

A triple structure with two MTs companies (one on top of the other) and a UK company on top of the MT holding, i.e. an MT Opco owned by an MT Holdco in turn owned by an UK HoldCo

This structure would enable fiscal consolidation at the level of the MT Opco and MT Holdco with the possibility to pay the 5% tax on corporate profits without the need to request any income tax refunds. Any dividends paid from MT HoldCo to UK HoldCo are not subject to any withholding taxes in Malta. The UK HoldCo will be acting as a tax neutral entity.

The triple structure is particularly attractive for international businesses seeking both tax efficiency and strategic flexibility. It combines the benefits of Malta’s fiscal regime with the versatility of a UK holding company. This is targeted towards individuals who are resident (non-domiciled) in Malta who want to operate from Malta within a tax-friendly and legitimate structure.