Group Taxation Provisions
Two companies that, for tax purposes, are resident exclusively in Malta, where one company has over 50% control over the subsidiary. Alternately, both companies have over 50% control of a third Malta-resident company, qualify as members of a group of companies.
Therefore, where assets (including shares, other securities and immovable property) are transferred between companies being members of the same group is deemed that no loss or gain has arisen from the transfer.
Maltese resident companies being members of the same group of companies may surrender and claim tax losses between them.