Hi,

I'm planning to register a company in Malta. The company is going to provide online service for clients around the world. As a US taxpayer I have the following assumption:

Malta is in the list of countries that have an income tax treaty with United States and meets requirements of section 1(h)(11)(C)(i)(II), so that dividends paid to US shareholders of Malta-based companies can be treated as "qualified dividends". Considering 5 percent effective corporate income tax rate on active income for Malta companies, my assumption is that overall tax liability for US shareholder of Malta-based company is 25%. Is my assumption correct or not?

Thanks!