// Tax · Mar 2026
Malta's Pillar Two implementation, what large groups need to track
Malta has confirmed phased implementation of the OECD Pillar Two 15% global minimum tax. The detail of how it interacts with the Maltese refund system is the key file to maintain.
Pillar Two introduces a 15% global minimum effective tax rate for groups above the EUR 750m revenue threshold. Malta's implementation has been confirmed with a phased approach.
For in-scope groups, the interaction between the Maltese refund regime and the Pillar Two top-up rules is the technical issue to manage carefully.
// What this means for your business
- If your group is in scope, prepare detailed effective-tax-rate computations per jurisdiction now, not at year-end.
- Refund-driven low effective rates may need to be paired with QDMTT (qualified domestic minimum top-up tax) modelling.
- Out-of-scope groups should still document position so changes in size or structure don't create surprises.
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Ministry for Finance, Malta