Biznes za granicą

Najpopularniejsza bandera Europy. Rejestrując jacht w tym kraju można zaoszczędzić fortunę

Przy okazji każdej kolejnej podróży na Maltę udaje nam się pozyskać najnowsze informacje o korzyściach płynących nie tylko z rejestracji spółek na tej niewielkiej wyspie, ale również z rejestracji jachtu na Malcie pod tamtejszą banderą, będącą najpopularniejszą banderą Europy i jedną z najpopularniejszych na świecie. Ponieważ dostajemy od Państwa wiele zapytań w temacie ulokowania swojego majątku na Malcie i rejestracji jachtu pod tą banderą, poniżej prezentujemy najważniejsze informacje.

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Rejestr statków na Malcie należy do jednych z największych na świecie. Założony we wczesnych latach 70- tych rozwinął się znacznie zarówno pod względem rozmiaru tonażu, jakim administruje, jak i reputacji, która cieszy się międzynarodowym uznaniem. Co najważniejsze, maltańska bandera oferuje wachlarz niedostępnych gdzie indziej korzyści, w tym przede wszystkim pod względem podatkowym.
Do głównych korzyści należy zaliczyć:

  • rejestrację jachtu, która może odbyć się w imieniu spółki maltańskiej jak i innego podmiotu, bez względu na jego narodowość,
  • niskie koszty założenia spółki, rejestracji jachtu oraz podatku tonażowego,
  • pełne zwolnienia podatkowe dla właścicieli jachtów,
  • brak ograniczeń w zakresie sprzedaży lub ustanowienia hipoteki na jachcie zarejestrowanym pod maltańską banderą,
  • bardzo dobrą reputację maltańskiej bandery, traktowanej jako godną zaufania na arenie międzynarodowej.

Sama procedura rejestracji jachtu dzieli się na rejestrację prywatną (jacht od 6 do 15 metrów długości, który nie przewozi pasażerów i służą do celów prywatnych jego właściciela) oraz handlową (jacht od 15 metrów długości i do 3000 ton wagi, nie przewożący ładunku i przewożący nie więcej niż 12 pasażerów oraz obsługiwany przez właściciela lub podmiot używający go w celach handlowych).
Rejestracją handlową, na której się skupimy możemy podzielić na:

  1. Jacht handlowy o długości od 15 do 24 metrów.
  2. Superjacht o długości od 24 metrów, nie cięższy niż 500 ton.
  3. Superjacht o długości od 24 metrów i o wadze od 500 ton do 3000 ton.

Na początku jacht jest rejestrowany tymczasowo na okres 6 miesięcy (termin ten może być wydłużony na kolejny okres, lub okresy nieprzekraczające łącznie sześciu miesięcy)  w trakcie którego wszystkie wymagane dokumenty powinny zostać złożone do rejestru w celu uzyskania stałej rejestracji.

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Certyfikat o wpisie do rejestru maltańskiego podlega odnowieniu w rocznicę jego rejestracji pod maltańską banderą. Jacht można zarejestrować również pod banderą Malty, jeśli jego właścicielem jest spółka zarejestrowana w innej jurysdykcji. W tym scenariuszu konieczne jest powołanie agenta, który reprezentować będzie właściciela jachtu na Malcie.
Schemat leasingu jachtu
Maltański system prawa zakłada specjalne zasady bazowane na Dyrektywie UE dotyczącej finansowania leasingu jachtów. Zasady te są atrakcyjne dla właścicieli jachtów, którzy używają Malty jako bazy dla importu lub nabyciu nowych jachtów z lub spoza UE. Leasing finansowy to umowa prowadząca do leasingowana jachtu przez leasingodawcę względem leasingobiorcy za opłatą i również wprowadzająca możliwość nabycia jachtu przez leasingobiorcę pod koniec okresu umowy za cenę będącą kalkulacją procentową wartości jachtu.
Jacht będący przedmiotem takiej umowy traktowany jest jak używany częściowo na wodach UE (w tym Malty) a częściowo poza UE i w konsekwencji, tylko część opłat licencyjnych przypisywanych jako wykorzystywane na terenie UE jest podstawą do opodatkowania maltańską stawką VAT. Ze względu na trudność w określeniu dokładnego czasu spędzonego na wodach UE i poza wodami UE, przepisy przewidują uproszczony procentowy udział leasingu automatycznie przypisywany przy wykorzystaniu jachtu na wodach UE. Ten procentowy udział opiera się na długości jachtu i sposobie jego napędzania. Choć opłaty licencyjne są przedmiotem standardowej maltańskiej stawki VAT tj. 18 %, to VAT w tym schemacie podlega pomniejszeniu zgodnie z poniższą tabelą:

Rodzaj jachtu Użycie na wodach UE Stawka VAT na Malcie Zaoszczędzony VAT
Jachty motorowe i jachty żaglowe ponad 24 metry długości 30% 5,4 % 12,6 %
Jachty żaglowe pomiędzy 20.01 a 24 metrami długości i jachty motorowe pomiędzy 16.01 a 24 metrami długości 40 % 7,2 %  10,8 %
Jachty żaglowe pomiędzy 10.01 a 20 metrami długości i jachty motorowe pomiędzy 12.01 a 16 metrami długości 50 % 9% 9 %
Jachty żaglowe do 10 metrów długości i jachty motorowe pomiędzy 7.51 a 12 metrami długości (gdy zostały zarejestrowane) 60 % 10.8 % 7,2 %
Jachty motorowe do 7,5 metrów długości (gdy zostały zarejestrowane) 90 % 16,2 % 1,8 %
Opcja wykupu 100 % 18 % 0 %

Aby skorzystać z powyższej ulgi podatkowej należy przestrzegać poniższych zasad:

  • licencjodawca musi myć maltańską sp. z o.o. zarejestrowaną do celów VAT na Malcie,
  • umowa leasingu musi obejmować okres nie dłuższy niż 3 lata,
  • umowa leasingu musi zawierać opcję wykupu jachtu po zakończeniu leasingu za wskazany w umowie procent wartości jachtu- w przypadku sprzedaży jachtu przy tej opcji podlegać będzie standardowej stawce VAT 18 %.
  • umowa leasingu i wartość jachtu musi zostać zaaprobowana przez Urząd Skarbowy przed rozpoczęciem obowiązywania umowy.

Dodatkowe ulgi podatkowe:

  • Malta wprowadziła pełne zwolnienie podatkowe od dochodu pochodzących od licencjonowanej organizacji żeglugi, która posiada, czarteruje lub eksploatuje statek o masie netto powyżej 1000 ton,
  • dochód pochodząca z żeglugi będącej licencjonowaną wysyłką jest zwolniony z podatku,
  • dochody i zyski ze sprzedaży lub innego transferu tonażu są zwolnione z opodatkowania na Malcie,
  • żaden podatek ani opłata skarbowa nie jest pobierana od sprzedaży udziałów w licencjonowanej organizacji żeglugi, która posiada, charteruje, obsługuje lub zarządza statkiem tonażowym,
  • licencjonowana organizacja żeglugi nie posiadająca dochodu lub uzyskująca dochód jedynie z żeglugi może złożyć roczną deklarację zamiast rocznego zeznania podatkowego,
  • dochód uzyskany przez zarządcę statku z działalności zarządzania statkami jest traktowany jako przychód uzyskany z żeglugi, a zatem jest zwolniony z podatku na Malcie. Przez pojęcie „działalność związana z zarządzaniem statkami” rozumie się m.in. działania, które polegają między innymi na załadunku czy zapewnieniu zarządzania technicznego statku.

 

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