Malta

Malta levies corporate income tax at 35%. However, Malta's imputation system allows shareholders to claim a refund of 6/7ths of the tax paid by the company on trading income. This reduces the effective rate to approximately 5%.

The refund is paid to the shareholder (not the company) after the company's tax is settled. This makes the structure more complex to administer than some alternatives, but it results in a fully EU-compliant low-tax structure.

Malta has extensive double tax treaty coverage, strong English-language legal infrastructure, and is part of the Eurozone. It's a credible, established EU jurisdiction with a track record in financial services, tech, and gaming.