Registration Time: 13.15
Sessions Time: 13.30 - 16.45 including a 15-minute break
Speaker: Dr. Robert Attard, Mr  Silvio Camilleri , Mr Christopher J Naudi and Ms Janica Aquilina
Venue: Online Webinar

Participation Fees (The Institute is now accepting payments via Paypal)
MIA Members: €40.00
Non-MIA Members: €75.00
Retired Members: €20.00
Students: €30.00

*Group bookings for 3 or more participants available.

Background Information

The Notional Interest Deduction (“NID”) was introduced with the aim of approximating neutrality between debt and equity financing by granting certain taxpayers a notional interest deduction with reference to certain risk capital employed in the production of certain chargeable income on an annual basis. The NID is determined by multiplying the qualifying risk capital with the applicable reference rate and is capped at 90% of the corresponding chargeable income. Moreover, as a consequence of claiming NID, the claimant’s shareholders would be attributed with deemed interest income equal to the NID claimed in Malta, hence the requirement for the claimant to obtain shareholders’ approval before claiming NID. Finally, the rules are also such that the NID interacts seamlessly with other concepts of Maltese tax law, including the Full Imputation System, the Group Consolidation Rules and the Flat Rate Foreign Tax Credit. The same however cannot be said for the Refundable Tax Credit System, given that the application of the NID could restrict the amount available for refund in terms of the said system. 

Objectives of the session

The session will initially provide a refresher of the Notional Interest Deduction Rules by going through the salient provisions thereof and subsequently will address certain practical aspects concerning the claiming of the NID by means of working out a number of examples and providing a brief overview of how the Tax Return Attachments to the Corporate Income Tax Return and Self-Assessment – namely TRAs 100 and 110A – must be completed.

TOPICS ON THE AGENDA• Eligibility to the NID, including:

• who is eligible to claim NID;
• which risk capital qualifies for NID; and
• against which income can NID be claimed;
• Determination of NID, including, numerical examples; and
• Claiming NID in the Corporate Income Tax Return and Self-Assessment;

Target Audience

Tax Advisors, Tax Representatives, Chief Financial Officers and Financial Controllers of companies forming part of multinational enterprises.

Speaker's Profile

Dr Robert Attard: Robert is EY Malta’s head of Tax with a long track record in all areas of tax law, a tenured senior lecturer at the University of Malta, a fellow of GREIT and member of the European Association of Tax Law Professors. In the IBFD’s 2015-2017 General Report on the Protection of Taxpayers’ Rights he was described as a well-known authority broadly experienced in the practical protection of taxpayers’ rights and a prominent member of the legal practice. Having served as a panellist at the 2015 IFA Congress he forms part of a study group of the International Law Association on the “Protection of Taxpayers’ Rights” (co-chaired by Advocate General Juliane Kokott and Pasquale Pistone) and is also a member of the Supervisory Council of the IBFD/IFA’s “Observatory on the Protection of Taxpayers’ Rights”. He has served as Visiting Professor at the University of Ferrara paying lecturing/speaking visits at Queen Mary (University of London), CTL (University of Cambridge), Salerno (with Wirtshaftsuniversitat Wien and Naples II) and the University of Palermo. The Maltese Court of Appeal has described him as a leading commentator on tax law referring to his publications in its judgements. Robert developed a detailed knowledge of tax aspects of the European Convention on Human Rights drafting submissions in cases filed against France, the Netherlands, Bulgaria and Malta. Robert is a published author on tax law publishing articles in European Taxation, EC Tax Review and the British Tax Review. He has contributed to several publications including a book published by Hart Publishing, 3 books published by the IBFD and several books published by the MIM. Philip Baker remarks that ‘Single-handedly, Robert is generating the literature which explains the structure and nuances of the system in Malta. One wishes other countries had similar authors who could write similarly enticing books to explain their tax codes.” Robert has argued most of Malta's leading tax cases including landmark judgments John Geranzi v. PM (right to justice within a reasonable time), Zahra v. PM (non bis in idem), Farrugia v. PM (taxation as a violation of the right to property) and Case 160 of 2012 (tax transparency).

Mr Silvio Camilleri:  Silvio is a Senior Manager within EY Malta’s Business Tax Advisory department. Silvio is an CPA by profession and joined EY Malta on a full-time basis in 2012. Initially, Silvio worked within the Business Tax Compliance department, wherein he has assisted both domestic and multinational corporate clients and individual clients in fulfilling their annual tax compliance obligations in Malta. After two years, Silvio moved on to the tax advisory arm of the firm and has since been advising clients on direct tax issues from both a domestic and an international perspective. Silvio lectures Maltese tax modules for ACCA and has successfully sat for the Advanced Diploma in International Taxation at the Chartered Institute of Taxation.

 Mr Christopher J Naudi: Chris is a Partner who is experienced in International Tax Services and is a Senior Partner in Tax Services provided by EY in Malta since 2001. He now heads the ACR – Accounting, Compliance and Reporting sub-service line of the firm. Until recently, he was the ITS Markets Leader for the Central and South-East Europe within EMEIA. He has professional experience in direct and indirect tax compliance, tax due diligence, corporate planning and reorganization and has substantial experience with cross-border transactions. Chris also spent several years working in the assurance sector, particularly assisting international client businesses and gaining seven years of experience in London and the Channel Islands. Chris is a Certified Public Accountant, a Fellow of the Institute of Chartered Accountants of England and Wales and a Fellow of the Malta Institute of Accountants. He is also a member of the Direct Tax Committee of the Malta Institute of Accountants and is a past examiner for the Institute. Chris is also a Member of the Malta Institute of Taxation. Chris is a Council member of the Institute of Financial Services Practitioners and a former President of this Institute and also sits on the tax sub-committees of the Institute. Chris is also a former Governor of FinanceMalta.

Ms Janica Aquilina: Janica is a Senior within EY Malta’s Business Tax Compliance department and a part-time lecturer for the Advanced Diploma in International Taxation. Janica is a CPA by profession and joined EY Malta on a full time basis in 2015 after graduating with a Master in Accountancy from the University of Malta. The client base which Janica has worked on is usually local and international companies in a number of diverse industries such as the manufacturing industry, the banking industry and the hospitality industry. In 2018 Janica has successfully 

EVENT CPE COMPETENCES

3 Hours Core 

WEBINARS TERMS AND CONDITIONS

Terms and conditions  apply

DISCLAIMER

By Registering and/or Booking for this event, you agree that MIA will collect your information, who will be using it as per the MIA Privacy Policy for CPE Events. Please read the MIA’s Privacy Notice for CPE Events in its entirety which can be found at this link. By accepting to participate in this event you accept that MIA shall process personal data in accordance with this Privacy Notice.

If registration is being affected by a company or other corporate entity on behalf of an attendee or the registering company or other corporate entity supplies to the MIA personal data of third parties, such as of employees, affiliates, management companies or service providers, the registering company or other corporate entity shall be solely responsible for making sure that the provision of such data to the MIA fully complies with applicable laws and the relevant person in regard to whom the data relates has been provided with the necessary information at law regarding the MIA’s processing of his personal data.
Any information notices, consents or other applicable requirements that may be required to be fulfilled for the provision of third party data to the MIA shall be borne solely by the registering company or other corporate entity. The registering company or other corporate entity hereby fully indemnifies the MIA and shall render the MIA completely harmless against all costs, damages or liability of whatsoever nature resulting from any claims or litigation (instituted or threatened) by any third party against the MIA as a result of the provision of any third party personal data to the MIA by the registering company or other corporate entity.

The Malta Institute of Accountants may take photos during this event. These images will be used by the Institute to share news about the event in newsletters, the Annual Report, The Accountant journal and printed publicity. Photos can also be published on MIA’s Facebook, Linkedln and Twitter. Such images may be used to publicise future events of the same nature and for reporting purposes.