https://www.um.edu.mt/library/oar/handle/123456789/82353 Sat, 11 Apr 2026 01:33:51 GMT 2026-04-11T01:33:51Z https://www.um.edu.mt/library/oar/handle/123456789/107477 Title: The introduction of tax consolidation group rules within the local context Abstract: Background and Purpose: On 18th May 2019, the Commissioner for Revenue issued LN 110 of 2019, which introduced tax consolidation rules in our local tax system. The main purpose of the study is to assess the perceptions and opinions of the parties involved, such as local tax practitioners. Possible impacts of the implementation of tax consolidation rules are also identified. Lastly, the study attempts to examine the new legislation from an international perspective. Design: The study involves gathering both secondary and primary data. Apart from analysing the available literature, the study achieves its aims by conducting interviews with ten local tax practitioners, two foreign tax practitioners, a Malta Institute of Taxation representative and a government official. Findings: The data gathered suggests that local tax practitioners and their clients welcome the new rules. Nonetheless, certain implications might affect tax practitioners, foreign entities and the local tax system in general. Apart from possible CFC implications on foreign entities, the local rules are not expected to have considerable foreign implications. Conclusion: The study concluded that tax consolidation rules are a useful alternative to the refund system. The importance of a cost benefit analysis was highlighted. In addition, clearer guidelines are needed to reduce any present grey areas. It was also suggested to reduce the auditing burden of the consolidated accounts and the present share participation threshold. Value: This dissertation aims to serve as a platform for respondents to express their opinions and concerns, while being of guidance to others. In addition, the study aims to provide worthy recommendations to the concerned authorities in order to improve its implementation. Description: M. Accty.(Melit.) Fri, 01 Jan 2021 00:00:00 GMT https://www.um.edu.mt/library/oar/handle/123456789/107477 2021-01-01T00:00:00Z https://www.um.edu.mt/library/oar/handle/123456789/103950 Title: Direct tax harmonisation is anathema to small economies within the EU Abstract: Purpose: The purpose is threefold: (i) to analyse whether the freedom to decide on tax matters is the only real tool left by which small economies can retain flexibility for the purposes of competing in a global economy; (ii) to evaluate whether the approximation of Member States’ systems of taxation is desirable or not; (iii) to understand whether a common front can exist between small EU economies as regards direct tax harmonisation. Design: A qualitative research approach drawing from legal constructivism has been taken, using intensive, elite, semi-scheduled interviews as the main technique. Findings: Seen against the purpose of the study, the findings show (i) that market size in particular, matters. Given the way in which Member States share competences with the EU, small economies defined by a small market size have limited macroeconomic and even microeconomic tools to ensure stable and sustainable growth. The freedom to decide on direct tax matters is critical in that respect. (ii) From an EU perspective, small economies recognise that a good balance between the needs of individual Member States and a ‘good’ international tax system must be achieved. Tax competition and tax transparency can coexist. (iii) Finally, a common ground on certain aspects may actually exist between some small economies in the background, but not all. Conclusions: (i) As important as this freedom may be, there are other important aspects that condition an economy’s competitiveness. (ii) From an EU perspective, instruments like the CCCTB, that promise transparency, but which implicitly restrict competition, are not likely to receive wide approval. (iii) The unique traits of each Member State, especially the level of sophistication of their systems of taxation, necessitates that they take a personal view of EU tax policy development. Value: It is hoped that in trying to achieve its purpose the study contributed in shaping an international tax system that meets both the needs of individual countries and the criteria of a good tax system. Description: M.A.(Melit.) Fri, 01 Jan 2021 00:00:00 GMT https://www.um.edu.mt/library/oar/handle/123456789/103950 2021-01-01T00:00:00Z https://www.um.edu.mt/library/oar/handle/123456789/103934 Title: Addressing the tax challenges of a digitalised economy : an analysis Abstract: Purpose: The primary objective of this dissertation is to assess the impact of digitalised business transactions within the international taxation sphere. In view of the current discussions held amongst international tax bodies, the proposals set forth have been analysed against predominant factors promoting accountability for digitalised activities, that is the Value Creation concept as well as a Destination-Basis principle for taxation. The subject has been put on top of the agenda by multiple States, as consensus for a multilateral approach is being sought. Design: Semi-structured interviews were conducted with high-ranking officers within the Office of the Commissioner for Revenue and Ministry of Finance, tax practitioners, international taxation scholars, and Members of the European Parliament. A qualitative approach was adopted, and open-ended questions were used. The data was collected and presented through the application of a thematic analysis. Findings: International taxation has been designed to suite brick-and-mortar businesses. The continuous innovation facilitated by digitalisation, trigger the need for a revision of the existing rules to capture transactions executed and concluded digitally. Conclusions: Whilst current tax laws need to be updated to capture a Permanent Establishment without the requirement of being physically present in a foreign State, the proposals set forward to date, direct a radical overhaul to the existing tax system. The technicalities involved, as set forth in said proposals, are critical and international pressure to reach consensus has been heightened from all over the globe. Implications: This subject area is gaining traction on an international level, and priority is being given by jurisdictions in order to obtain a uniform approach. Media attention is amplified as significant efforts are constantly being displayed by legislators, tax practitioners and governments alike. It is therefore timely to investigate the international tax reform proposed by the EU and the OECD, particularly since this shall have a considerable impact on various key players, whatever the outcome. Description: M.A.(Melit.) Fri, 01 Jan 2021 00:00:00 GMT https://www.um.edu.mt/library/oar/handle/123456789/103934 2021-01-01T00:00:00Z https://www.um.edu.mt/library/oar/handle/123456789/103932 Title: Tax amnesty : how can policymakers design the most effective model Abstract: Purpose: The principal purpose of this dissertation is to identify what are the main characteristics that a tax amnesty scheme should include for it to achieve the desired objectives. Furthermore, aspects such as the compliance effects of tax amnesty schemes were also reviewed to establish the post-amnesty behaviour of taxpayers after the termination of a tax amnesty scheme. Design: Different branches of research were explored to arrive at the objectives of the study. Tax amnesty schemes from different countries in Europe were analysed with the intention of drawing out their characteristics and determining which helped achieve the desired goals. Subsequently, the post-amnesty compliance behaviour was analysed through a detailed analysis of a particular scheme implemented in Malta together with data collected from a survey distributed to tax officials, taxpayers and tax representatives. Furthermore, data was also collected through a database, created for the purpose of these studies, on tax amnesty schemes implemented in Malta between 2009 and 2020. Findings: From the research conducted, it was established that a tax amnesty scheme should be a one-time policy. Furthermore, other important characteristics include the duration of the scheme and pardoning from legal and criminal prosecution. It was also determined that no anonymity should be granted to participants as this would hinder the tax authority’s ability to carefully monitor previously non-compliant taxpayers in the future. The importance of exchange of information with various institutions was also deemed to be a key characteristic that should accompany the implementation of such a scheme. Furthermore, to the post-amnesty compliance behaviour of taxpayers, it was established that this is primarily related to the reoccurrences of tax amnesty schemes. If tax amnesty schemes are implemented repeatedly the compliance rate of both previously compliant and non-compliant taxpayers is influenced in a negative manner. Conclusions: It was therefore recommended that a tax amnesty scheme should only be implemented as a one-time policy. Suggestions were made as to how the same results can be achieved through alternative policies. Ultimately, it was also recommended that tax authorities should seek to focus their ability on the source of the problem of any tax arrears, that is, weak compliance by strengthening the legal framework. Value: The established characteristics should help promote a tax amnesty that achieves its goals whilst taking into consideration factors of future compliance and equity. Furthermore, a detailed overview of tax amnesties implemented in Malta serves as my contribution to this dissertation gathering tax amnesty schemes implemented in Malta in the past ten years into one study, data which is not currently available in any other literature. Description: M.A.(Melit.) Fri, 01 Jan 2021 00:00:00 GMT https://www.um.edu.mt/library/oar/handle/123456789/103932 2021-01-01T00:00:00Z