The Malta Tax and Customs Administration (MTCA) has introduced new mandatory transfer pricing disclosure requirements for businesses with cross-border related‑party transactions. TRA 135, the new mandatory transfer pricing attachment to the income tax return is applicable for the year of assessment 2026 (financial year ended 2025).
What is TRA 135?
TRA 135 requires taxpayers to carry out a formal assessment of whether the Maltese Transfer Pricing Rules apply to their cross-border related-party arrangements. Where the rules apply, taxpayers must disclose relevant information relating to those transactions within the income tax return.
Where the Maltese Transfer Pricing Rules do not apply, taxpayers are still required to complete TRA 135 by clearly outlining the reason for non-applicability. This may include, for example, the application of the SME exemption, grandfathering provisions or exclusions under Rule 9 of the Maltese Transfer Pricing Rules.
What information needs to be disclosed?
Where TRA 135 is applicable, taxpayers are required to disclose structured information, including:
The business activity of the associated enterprise.
The name and jurisdiction of the associated enterprise.
Description of the arrangement in scope.
The transfer pricing methodology applied.
The transaction value and the corresponding arm’s length amount.
These disclosures are in addition to any Master File and Local File documentation requirements that may already apply under the Maltese Transfer Pricing Rules.
What you need to do now
If your business has cross‑border related‑party transactions, unless you have already done so, you’ll need to take proactive steps now to meet the new disclosure requirements. This includes reviewing existing arrangements, assessing the applicability of the Maltese Transfer Pricing Rules and ensuring that appropriate documentation and data are in place to support the disclosures required under TRA 135.
How can we help?
We work alongside your tax and finance teams to assess the impact of these rules on your structure and support timely, accurate disclosures.
Our transfer pricing team can assist in the preparation of the required TRA 135 disclosures together with the Maltese Local File, ensuring full and timely compliance with the reporting requirements.
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