01/09/2026
🚨 TRA 135 is here. Malta's new mandatory transfer pricing disclosure applies for the first time in 2026—and it's not optional, even if you conclude the Rules don't apply to you.
The real challenge? It's not just completing a form. It's ensuring your transfer pricing framework, documentation, and data governance tell a coherent story to the MTCA.
Five critical areas to assess now: ✓ Scoping conclusions (SME status, de minimis thresholds, grandfathering) ✓ Policy alignment with current business models ✓ Consistency across tax returns, financials, and Master Files ✓ Evidence for outcomes that may attract scrutiny ✓ Operational readiness of your data systems
The first filing sets the baseline.
Get it right. 👉 https://delo.tt/6184B1fRbO
Understand Malta's new mandatory TRA 135 transfer pricing disclosure requirements for 2026. Learn scoping rules, documentation standards, and how to ensure your cross-border related-party arrangements are compliant and defensible. Learn more...