Why are Malta's 5 percent not what they look like?

Because you do not get them straight away. The Maltese company pays 35 percent first. Only afterwards does the shareholder reclaim 30 points through a refund application. That requires a Maltese tax number of their own, the application itself, and in practice six to nine months of waiting for the money. During that time the capital sits with the Maltese treasury rather than with you. On top of that, how German tax offices treat this route is not settled. Factor in the running cost of such a structure and the lead over Bulgaria melts down to a few thousand euros. Malta is also an island, as is Cyprus. General information, not tax advice.