Malta`s rules are modelled on Articles 7 & 8 of Council Directive 2016/1164. Therein, a CFC is one, whereby "the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity"