Malta: Tax treatment of securitisation vehicles

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Malta: Tax treatment of securitisation vehicles

vella.jpg

cassar.jpg

Donald Vella


Kirsten Cassar

Securitisation is an essential means of raising finance and Malta's flexible framework creates scope for a wide range of transactions. Maltese law provides for a number of securitisation structures, all of which may benefit from the applicable fiscal treatment. It is pertinent to note however that recently the Maltese legislator has clarified that the regime applicable to Maltese securitisation vehicles has, in some aspects, limited application to reinsurance special purpose vehicles established in Malta, to which specific regulations apply. The flexibility of the securitisation regime finds its ground in the extensive range of assets which may be securitised through a Maltese vehicle. Any asset may be securitised, whether existing or future, movable or immovable, tangible or intangible, and where the context so allows, risks. This implies that both traditional assets, such as trade receivables, mortgage loans, life insurance policies, tangible and intangible assets as well as risks relating to obligations or liabilities assumed by third parties may be the subject of a securitisation transaction.

Taxation of the securitisation vehicle

The tax position of securitisation vehicles in Malta is generally neutral. Special purpose vehicles established in Malta are taxable in Malta under the normal income tax rules at the standard corporate income tax rate of 35%. However, substantial deductions are available.

Specifically enacted tax regulations clarify that the following deductions may always be availed of by a securitisation vehicle:

  • Cost of acquisition: Expenses payable to the originator for the acquisition of securitisation assets or the assumption of risk;

  • Finance expenses: Premiums, interest or discounts relating to financial instruments issued, or funds borrowed, to finance the acquisition of securitisation assets or the assumption of risks;

  • Operating expenses: Costs incurred in the day-to-day administration of the securitisation vehicle and the management of the securitisation assets, including the collection of any relevant claims.

After the aforementioned deductions are taken, the securitisation vehicle may opt to claim a further deduction on its remaining taxable income, thereby typically ensuring no taxation at the level of the securitisation vehicle. The deductions, including the further deduction, constitute deemed income for the originator. However, no tax is payable in Malta on such deemed income where the originator is not resident in Malta for tax purposes.

Donald Vella (donald.vella@camilleripreziosi.com) and Kirsten Cassar (kirsten.cassar@camilleripreziosi.com)

Camilleri Preziosi

Tel: +356 21238989

Website: www.camilleripreziosi.com

more across site & shared bottom lb ros

More from across our site

Complex and constantly shifting rules on global mobility mean ‘the risk is too great’ for staff to work abroad on personal time, EY’s Maureen Flood tells ITR
While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness
Rising demand for specialist expertise has fuelled the growth in tax partner headcounts, Cain Dwyer found; in other news, Switzerland has been urged to reconsider pillar two
An OECD report on the taxation of the digital economy is expected by the end of 2026, according to the group of nations
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
As demand for complex, cross-border private client counsel spikes, Patrick McCormick sees opportunity in starting from scratch
As part of an exclusive global alliance, KPMG will become one of Anthropic’s ‘preferred consultants’ for private equity
In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
Jurisdictions have moved to ensure that multinationals are not punished for late GIR filings due to a lack of available filing portals or exchange relationships
HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation
Gift this article