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Assistance with Requests for Information (RFI) from the Malta Tax and Customs Authority (MTCA)

Summary

Companies operating in or through Malta may, at various stages of their lifecycle, receive a Request for Information (RFI) from the Malta Tax and Customs Authority (MTCA) or the Office of the Commissioner for Revenue. These requests are formal, time‑bound and often detailed, requiring careful coordination, accurate documentation, and clear explanations aligned with Maltese tax law and international information‑exchange standards.

At Chetcuti Cauchi Advocates a, we regularly assist Maltese and international clients with the drafting, coordination and submission of RFI responses, ensuring that communications with the MTCA are complete and consistent.

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What is an RFI ?

An RFI is a formal request issued by the MTCA - often by the Office of the Commissioner for Revenue - seeking specific information or documentation in relation to a company, trust, or structure. RFIs are commonly issued in the context of:

  • Exchange of Information (EOI) obligations
  • Monitoring of compliance with Maltese or foreign tax legislation
  • Verification of legal and beneficial ownership
  • Review of accounting records and transaction flows
  • Confirmation of record keeping, data retention and governance procedures

These requests may relate to Maltese entities, cross border structures, or international groups, and frequently involve coordination across multiple stakeholders, jurisdictions, and service providers.

RFIs are typically issued with specific deadlines and require a formal written response, supported by relevant records and documentation.

Why RFIs Require Careful Handling

Although an RFI is not, in itself, an allegation of wrongdoing, the quality and consistency of the response is critical. Incomplete, inconsistent or poorly structured replies may lead to:

  • Follow up requests and prolonged scrutiny
  • Escalation to formal audits or assessments
  • Increased regulatory exposure for directors, shareholders or fiduciaries
  • Reputational risk for the entity and its service providers

Responding effectively requires more than simply collating documents - it involves understanding the regulatory context, aligning disclosures across registers and filings, and presenting information in a clear and structured manner.

Our RFI Support Services

We may provide structured, end to end support to clients who receive Requests for Information (RFIs). Our role is to assist with the coordination, drafting and submission of complete, accurate responses, tailored to the specific facts and structure of each case.

Our support typically includes:

  • Review of the RFI to understand its scope, context and information requirements
  • Coordination of relevant documentation and stakeholders, including directors, shareholders, fiduciaries and external advisors
  • Preparation of clear, factual and proportionate written responses addressed to the MTCA
  • Assistance with timely submission and follow up communications, where clarification is requested

This approach allows clients to respond to RFIs in a controlled, consistent and professional manner, while ensuring that communications with the MTCA are clear, complete and aligned with regulatory expectations.

Experience with Complex and Cross Border Structures

Our team regularly assists with RFIs involving:

  • Maltese companies with foreign shareholders or beneficiaries
  • Fiduciary shareholding and trust arrangements
  • International holding and financing structures
  • Record-keeping and compliance matters

We understand the practical challenges that can arise when responding to information requests covering multiple years, jurisdictions or service providers - and we help clients navigate these efficiently and professionally.

How We Can Help You

If your company or structure has received a Request for Information from the Malta Tax and Customs Authority, early and structured support can make a material difference to the outcome and efficiency of the process.

We offer practical, experienced assistance to help you:

  • Understand the scope and implications of the RFI
  • Prepare a complete response
  • Coordinate stakeholders and documentation efficiently
  • Communicate with the authorities.

Contact our Corporate & Trusts team to discuss how we can support you with the drafting and delivery of your MTCA RFI response.

Frequently Asked Questions (FAQs)

[question]What is a Request for Information (RFI) from the MTCA?[/question]

[answer]A Request for Information (RFI) is a formal written request issued by the Malta Tax and Customs Authority, often by the Office of the Commissioner for Revenue, asking for specific information or documentation relating to a company, trust or structure. RFIs are commonly issued as part of routine compliance checks or information exchange processes and usually require a written response within a specified timeframe.[/answer]

[question]Is receiving an RFI a sign that something is wrong?[/question]

[answer]Not necessarily. Receiving an RFI does not automatically indicate wrongdoing or non compliance. In many cases, RFIs are issued as part of standard monitoring, verification or information exchange processes. That said, RFIs should always be handled carefully, as the clarity and completeness of the response can influence whether further questions are raised.[/answer]

[question]Can you assist if the RFI relates to earlier years or cross border structures?[/question]

[answer]Yes. We regularly assist clients with RFIs covering historic periods or records and structures involving multiple jurisdictions. This includes coordinating information held by different parties and ensuring that responses are consistent and supported by available documentation.[/answer]

[question]Do you communicate with the MTCA on our behalf?[/question]

[answer]We assist with the drafting, coordination and submission of RFI responses and support clients in preparing clear and structured communications addressed to the MTCA. Where required, we also assist with follow up correspondence to address any clarification requests, in line with the client’s authorisations and instructions.[/answer]

[question]When should we seek assistance with an RFI?[/question]

[answer]It is generally advisable to seek assistance as early as possible after receiving an RFI. Early involvement allows sufficient time to review the request, gather the necessary information and prepare a clear and complete response, reducing the risk of delays or follow up requests.[/answer]

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