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FITWI Regime (Final Income Tax Without Imputation)

The FITWI regime is an optional Maltese corporate tax regime: instead of the imputation system, companies and trusts can elect a final 15 percent tax with no refund to shareholders. It does not apply to individuals.

FITWI stands for Final Income Tax Without Imputation. The regime was introduced by Legal Notice 188 of 2025, published on 2 September 2025. It can be elected by companies, bodies of persons treated as companies and trusts, which then pay a final tax of 15 percent on their chargeable income. On distribution there is neither an imputation credit nor a refund to shareholders. FITWI sits alongside the full imputation system with 35 percent corporate tax and the 6/7 refund; it does not replace it. The election is binding for five years. The regime does not set a fixed minimum tax amount.

There is no FITWI for individuals. The combination it is often confused with, 15 percent with a minimum tax of EUR 15,000 a year, belongs to Malta's residence programmes: the Global Residence Programme (GRP) for nationals of countries outside the EU, the EEA and Switzerland, which since Brexit includes UK nationals, and the Residence Programme (TRP) for EU, EEA and Swiss nationals. Both tax foreign income remitted to Malta. For applications made from 2027, the minimum tax rises to EUR 35,000.

Last updated: October 13, 2026

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