The DDT10 Exemption

Here’s a clear explanation of the DDT10 Exemption in Malta — what it is, how it works, and why it matters for companies.

What Is DDT10?

DDT10 is an exemption granted under Article 47 of the Duty on Documents and Transfers Act in Malta. It is commonly referred to as the “DDT10 exemption” and primarily relates to stamp duty treatment and certain corporate tax compliance obligations.

In practical terms, DDT10 is a formal determination issued by the Commissioner for Revenue. Once granted, it exempts an eligible company from specific stamp duty charges and may provide extended tax compliance deadlines that would otherwise apply under the Act.

What Does the DDT10 Exemption Do?

1. Stamp Duty Relief:

   It can exempt the company from paying stamp duty on transfers of marketable securities (like share transfers) that would otherwise attract duty. This can make share transfers less costly and simpler.

2. Extended Tax Payment Deadline:

   Normally, companies must pay corporate tax within 9 months after the financial year-end. If granted the DDT10 exemption, this deadline can be extended to 18 months after the financial year-end. This gives businesses more time to settle their tax liabilities.

3. Provisional Tax:

   Companies with a DDT10 exemption may not be required to make provisional tax payments during the year.

Who Can Get the DDT10 Exemption?

To qualify, a company typically must show that:

✔️ More than 90% of business activities are carried out outside of Malta 

✔️ Turnover is not from local Maltese customers or from foreign clients operating in Malta through a local branch

✔️ Turnover isn’t from Malta-based retail, hospitality, manufacturing, transport, agriculture or property activities

✔️ Majority of shareholding is held by any person who is not resident in Malta and who is not owned and controlled by, directly or indirectly, nor acts on behalf of an individual/s who are ordinarily resident and domiciled in Malta

Important Notes About DDT10

• DDT10 is not automatic: Companies must apply to the Commissioner for Revenue and get the determination issued.

• It is not indefinite: Determinations aren’t permanent — companies will need to renew them (usually every 3 years) to continue benefiting from the exemption.

• The exemption applies both to duty on documents and transfers and certain corporate tax timing benefits.

• If a company doesn’t satisfy the relevant conditions or the determination lapses, normal stamp duty rules and tax deadlines apply.

  
  
  
  

SUMMARY

If a company is mostly foreign-focused — with little to no business conducted in Malta itself, it may qualify for DDT10.

Feature	Normal Rule	With DDT10 Exemption
Stamp Duty on Share Transfers	Pay duty	Exempt
Corporate Tax Deadline	9 months after year-end	18 months
Provisional Tax	Required	Often not required

At MCP Accountancy Services, we understand that navigating Malta’s tax landscape and exemptions like DDT10 can be complex. We can guide your company through the eligibility assessment, application process, and ongoing compliance requirements, ensuring you maximize the benefits of this exemption while staying fully compliant.