How is the Single Malt different from the Double Irish?

The shape is almost identical, but the low-tax destination changes. The Double Irish parked profit in Bermuda using Ireland's old management-and-control residency rule. The Single Malt parks it in Malta using an out-of-date bilateral treaty. When Ireland closed the first route, the second was still open, so the structure migrated.

Why did a treaty gap make this possible?

Tax treaties are negotiated one pair of countries at a time and updated slowly. The OECD's multilateral instrument was designed to patch many treaties at once with a common anti-abuse rule. Until that instrument took effect for both Ireland and Malta, their older treaty lacked the test that would have denied the structure, and that delay was the opening.

The Single Malt, Explained

ByLoopholeKiln EditorialPublished17 June 2026

Figures current as of1 January 2026·Corrections

← The Named Tax Structures, Explained: Double Irish, Dutch Sandwich, Single Malt and the Rest

When the Double Irish was being phased out, a near-identical replacement appeared. The Single Malt swapped Bermuda for Malta and exploited a gap in the tax treaty between Ireland and Malta. It produced the same outcome: profit parked in a low-tax jurisdiction. Ireland and Malta agreed to shut it on 27 November 2018.

What it is

A successor to the Double Irish that uses the bilateral tax treaty between Ireland and Malta rather than the old Bermuda residency trick. When Ireland closed the Double Irish, it changed the rule that let an Irish-registered company be resident in a zero-tax island. But a separate route remained: the Ireland-Malta treaty had not yet been updated with the OECD's anti-avoidance provisions, in particular the "principal purpose test." That gap let an Irish-registered company be treated as tax-resident in Malta instead, achieving much the same result.

How it works, step by step

A US parent licenses its intellectual property to a company that is registered in Ireland but tax-resident in Malta. Because the Ireland-Malta treaty pre-dated the OECD update that would have blocked it, Ireland accepted the company as Maltese-resident.
That company sub-licenses the intellectual property to a second company, registered and resident in Ireland, which runs the actual operations.
The Irish operating company pays royalties up to the Maltese-resident company.
Malta charges no withholding tax on royalties it receives, and taxes the income at a very low effective rate once its refund system is applied.
The profit now sits with the Maltese-resident company at a near-negligible rate, replicating the Double Irish result with Malta standing in for Bermuda.

Who used it

The structure was first described publicly by the charity Christian Aid, which revealed the Single Malt in 2017. In a 2021 briefing, Christian Aid Ireland alleged that a US-headquartered medical-devices and diagnostics group used an arrangement it described as similar to the Single Malt, and estimated that at least 477 million euros of profit from that group's rapid diagnostic test business, including its COVID-19 tests, could be sheltered from Irish and Maltese tax this way. The group has publicly denied ever using the Single Malt structure and says it complies with all applicable tax laws. We set out the NGO's estimate and the company's denial side by side; we are not asserting which is right.

Is it still open, and when did it close

Closed. Ireland and Malta signed a Competent Authority Agreement, announced on 27 November 2018, confirming that once the OECD's multilateral anti-avoidance convention took effect in both countries, the treaty would no longer permit the Single Malt. Ireland's side of that convention entered into force on 1 May 2019. The structure is closed prospectively from that point.

A note on dates: you will sometimes see the Single Malt described as closing in 2025. That is wrong. The closing agreement was reached in November 2018. There was no 2025 agreement.

Sources