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Ireland vs Malta: which jurisdiction wins?

Ireland vs Malta — both credible, very different trade-offs. Below: side-by-side on the variables that actually move the decision.

 IrelandMalta
Tax headline12.5% trading, 15% Pillar 2 for large groups35% headline, ~5% effective via refund system
Formation days57
First-year cost$5,500$4,500
Treaties75+70+
SubstanceSubstance critical (CFC, BEPS)EU substance requirements + DAC6
BankingBOI, AIB, plus US bank branchesBank of Valletta, APS, plus EU EMIs

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