US Firms Utilized Malta Subsidiaries to Lower Tax Bills
Public companies used offshore structures to shift profits, leveraging a 2029 grace period for minimum tax rules.
Updated on Sept. 29, 2026 in Corporate Finance
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In 2026, new accounting disclosure rules highlighted how U.S. corporations utilized Malta-based subsidiaries to lower their global tax obligations. These structures allow firms to shift profits to jurisdictions currently exempt from the 15% global minimum corporate tax.
Why it matters
Companies utilize these offshore arrangements to maximize bottom-line profitability and secure competitive advantages by reducing effective tax rates. The strategy remains effective for now because the European Union granted Malta a delay in implementing the 15% minimum tax.
Crocs reduced its tax bill by $218 million in 2023 using a Malta-based subsidiary. Malta currently operates under a 15% global minimum tax implementation deadline of 2029.
The players
Crocs
A Broomfield, Colorado-based footwear company that operates as a major global manufacturer and retailer.
President Donald Trump
The current President of the United States who announced the country's withdrawal from the global tax effort in 2025.
Thermo Fisher
A large-scale multinational life sciences company that maintains a presence in offshore jurisdictions.
Victoria's Secret
A global retail brand specializing in lingerie and beauty products.
Skechers
A large footwear manufacturer and retailer known for its global distribution network.
The details
Companies establish subsidiaries in Malta, often maintaining offices that consist of little more than a plaque on a building with minimal or no permanent staff. By routing profits through these entities, parent firms are able to shift taxable income out of higher-tax jurisdictions. This practice persists as U.S. parent companies navigate international regulatory environments, including the current U.S. decision not to participate in the global minimum tax effort.
Timeline
2023 was the year Crocs reduced its tax bill by $218 million.
January 2025 marked the announcement of the U.S. withdrawal from the global tax effort.
2026 was when the new accounting disclosure rules took effect.
2029 is the deadline for Malta to implement the 15% minimum tax.
Market Landscape
This activity follows the pattern of companies exploiting implementation gaps in the 15% global minimum corporate tax. Firms continue to prioritize jurisdiction-based profit shifting as a counter-strategy to global regulatory efforts.
Operators should review their international tax exposure and monitor which jurisdictions retain exemptions from global minimum tax standards. Consult with a qualified accountant to understand if pending global tax reforms will impact your entity's current tax-planning strategies.
The takeaway
Tax optimization strategies frequently evolve to exploit specific regional grace periods provided by international accords. Operators should track the 2029 implementation deadline in Malta and monitor future SEC disclosures for shifts in corporate entity strategies.
Further reading
For broader analysis on how regulatory shifts impact enterprise value, visit Corporate Finance.
Source note: This article includes information reported by Colorado Public Radio.
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