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DIR 05/25 | On the Reporting of Measurements in Compliance Checks

1. Purpose

This Directive establishes a uniform standard for the rounding and reporting of measurements by members of the profession when carrying out compliance checks against statutory requirements or regulatory provisions. The purpose is to ensure consistency, clarity, and alignment with the units and precision specified in the applicable laws, regulations, and policies.

 

2. Scope

This Directive applies to all periti undertaking compliance checks, inspections, or certifications where reference is made to dimensional or quantitative requirements established in Maltese law, subsidiary legislation, or official policy documents.

 

3. Principle of Alignment with Regulation

  1. Measurements reported in compliance checks shall have the same number of decimal places as prescribed in the referring regulation, policy, or statutory instrument.
  2. Where the regulation specifies two decimal places, the measurement shall be reported to two decimal places, irrespective of the precision of the measuring instrument.
  3. Where the regulation specifies a single decimal place, the measurement shall be reported to a single decimal place.
  4. Where no decimal points are specified in the regulations, the measurement shall be reported to two decimal places.

 Example A:

 Example B:

    • Sub-regulation 16(1) of the same Regulations prescribes distances in backyards and internal yards to one decimal place in its tabulated provisions. Accordingly, all reported measurements of such distances shall be rounded and reported to one decimal place.

 Example C:

    • Sub-regulation 12(a) of the same Regulations prescribes that the minimum cumulative external aperture of habitable spaces in text with no reference to any decimal places. In such cases, all reported measurements of such distances shall be rounded and reported to two decimal places.

4. Rounding Convention

  1. The Kamra tal-Periti is hereby adopting the rounding convention known as “rounding half away from zero” (commercial rounding).
  2. Under this system:
    • Values equidistant between two representable numbers shall be rounded to the nearest value away from zero.
  3. For clarity:
    • Measurements between 2.591m and 2.594m shall be rounded down to 2.59m.
    • Measurements between 2.595m and 2.599m shall be rounded up to 2.60m.

 

5. Application and Effective Date

  1. All compliance reports, including valuation reports and bank forms, submitted by periti after the date of effect of this Directive shall conform to the above principles.
  2. This Directive shall enter into force on 1st September 2025.

 

Perit André Pizzuto
President

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UPDATED ON 29/08/2025 TO INCLUDE FOR SITUATIONS WHERE NO DECIMAL PLACES ARE SPECIFIED.
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CIR 05/24 | Update on Tender for Property Valuations issued by CFR (2)

In 2022, the Council of the Kamra tal-Periti was alerted to a tender published by the former Commissioner for Revenue (CFR), now renamed Malta Tax & Customs Administration (MTCA), calling for periti to draw up property valuations at a capped rate of €25 excluding VAT.

The Council had immediately issued a directive instructing periti not to submit bids for this tender due to its “unacceptable terms, which undermine the scope of the due diligence and research necessary for the preparation of a valuation report, as well as underestimate the associated liabilities”.

Urgent meetings were held with the Commissioner for Revenue and Director of Property Tax to discuss the way forward. Given that the tender could not be amended following its publication, an agreement was reached such that following its closing date, the CFR would republish the tender with fresh terms in agreement with the Council of the Kamra, including considerably improved financial terms that reflect the dignity and respect we should all expect for our profession.

The above background history was explained in a circular published soon after. A meeting was also held with a number of periti who had already been giving similar services to the CFR for a number of years through an arrangement which the National Audit Office declared to be non-conformant with the public procurement regulations. They were also kept regularly informed of meetings and communications exchanged between the Council and the CFR, and were in agreement with our approach.

 

Regretfully, a number of periti –  indeed the same periti who were being kept continuously informed about the ongoing negotiations – chose to outmanoeuvre the Council to try to gain an advantage over ethical and responsible members of the profession who chose to diligently follow the directive and await the outcome of the negotiations the Council was conducting. This resulted in a wholly unnecessary two-year delay during which members of the profession could have benefitted from the improved terms eventually negotiated, which we are happy to announce below.

 

Indeed, rather than the measly and demeaning sum of €25 excl. VAT per report, as a result of our negotiations successful bidders will be earning €50 excl. VAT per report for all properties having a contract value of less than €1 million, and €150 excl. VAT per report for all properties having a contract value of €1 million or more.

The Council considers this a suitable compromise, considering also that the use of the term “valuation” has been dropped from the tender document in favour of the term “review”. This shift in terminology is felt to more appropriately reflect the actual exercise to be performed by periti who successfully bid for the new tender.

The tender published by the MTCA via the Department of Contracts is linked below:

CfT: CT2136/2024 – Framework Agreement for the Provision of Professional Services of Periti to provide reviews of Properties to the Malta Tax and Customs Administration (MTCA)

 

The Council looks forward to building further on the positive relationship established with the MTCA, and remains committed to representing the interests of the profession at all times to the best of its abilities.

 

Perit André Pizzuto
President

 

 

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CIR 02/23 | Rural Lease Valuations

The Council of the Kamra tal-Periti has been alerted to a legal notice directing periti to produce fictitious values for agricultural land that have no underpinning in the market.

It appears that the purpose of this exercise is to artificially contain the value of farmland, and direct periti away from reporting a fair market value in line with international and national valuation standards.

In view of the above, the Council is advising periti not to file valuation reports in accordance with such legal notice until further notice as such reports may give rise to potential professional negligence, besides exposing periti to litigation by aggrieved parties due to the apparent unconstitutionality of such subsidiary legislation.

 

Perit André Pizzuto
President

 

 

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CIR 09/22 | Update on Tender for Property Valuations issued by CFR

Further to Directive DIR 08/2022, the Council met with the Commissioner for Revenue, Mr Joseph Caruana, and the Director of Property Tax, Ms Josette Galdes on 12th August 2022. During this meeting the Council outlined its serious misgivings about the tender, particularly relative to the capping of €25 per valuation report and €25 per Court sitting. The Council also pointed out that there is no mention of remuneration for disbursements, such as acquiring planning permits from the PA, and that such remuneration fees would inevitably affect the quality of the valuations being provided.

 

During the meeting the CFR stated that it understood the nature of the Kamra’s objection, and expressed its openness to introducing differential rates, distinguishing between the valuation of garages and hotel resorts, which would have otherwise all been compensated for at the capped rate of €25.

It was agreed that the CFR would consult with the Department of Contracts (DoC) to establish whether the tender as published could be amended. However, the CFR was not willing to withdraw and republish the tender should this not be possible.

 

On 16th August 2022, the CFR informed the Council that the DoC was unable to amend the tender.

 

Given the above, the Council is notifying members of the profession that the only resolution to the matter is allowing the current tender to run its course without any bids, so it may be republished after appropriate consultation is made with the Kamra in accordance with article 4 of Subsidiary Legislation 390.01.

 

Moreover, the Council shall retain Directive DIR 08/2022 in place. Members of the profession are reminded that disciplinary action will be taken against periti who do not abide by the Directive.

 

Perit André Pizzuto
President

 

 

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DIR 08/22 | Tender on Property Valuations issued by CFR

The Council of the Kamra tal-Periti has been notified of a tender issued by the Commissioner for Revenue with reference SPD7/2021/081 named “SERVICES – FRAMEWORK AGREEMENT FOR THE PROVISION OF PROFESSIONAL SERVICES OF PERITI TO PROVIDE VALUATIONS OF PROPERTIES TO THE COMMISSIONER FOR REVENUE (CFR)”.

The tender stipulates that “[v]aluations of properties is capped at a fixed fee of twenty-five Euro (€25.00) excluding VAT”. These are unacceptable terms, which undermine the scope of the due diligence and research necessary for the preparation of a valuation report, as well as underestimate the associated liabilities.

 

In view of the above, the Council is hereby instructing all Periti not to submit bids for this tender.

Failure to abide with this Directive will result in disciplinary action.

 

Perit André Pizzuto
President

 

 

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NSO issues call for Statistical Services for Construction Survey 2018

The National Statistics Office is inviting submissions from persons/organisations interested in the provision of services related to construction projects. The Construction survey forms part of the Purchasing Power Parities Survey.  Pricing a construction project involves collecting unit prices with which to value its components and summing the values obtained to arrive at a total price for the project. PPPs for construction are calculated with the total prices for a set of construction projects. The set covers three types of structures: residential buildings, non-residential buildings and civil engineering works.

Interested persons/organisations shall include in their proposals the following information:

a) Name of submitting person(s)/organisation;

b) Contact information for person(s) authorised to represent the submitting person(s)/organisation;

c) A outline brief of how the above mentioned objectives will be meet;

d) An indication of the expenditure outlays of the entire project.

Those interested should submit their proposals to the Prices Unit, National Statistics Office by not later than the 16th of March 2018 by e-mail on denise.magrin@gov.mt.

Call for Quotations
Annex 1
Annex 2
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Lands Authority clarifies the issues raised by KTP on Property Valuations EOI

Following the call for Expressions of Interest for periti to provide property valuation services to the Lands Authority, the latter had organised an information session for periti which was held last October. A number of our members had contacted the Kamra tal-Periti to request clarification on a number of issues raised during such meeting.

The Council had set up a working group to address these issues, and had written to the Lands Authority outlining these matters. The issues raised include valuation methodologies to be adopted, payment of professional fees, and timelines for the drawing up of reports among other things.

 

The Authority has responded. Please refer below to the correspondence exchanged between the Kamra and the Lands Authority. Should you have any comments, it would be appreciated if you could forward to the Kamra by not later than the 30th March 2018 on info@kamratalperiti.org.

KTP letter to Lands Authority | 21/10/2017
Reply from Lands Authority | 12/02/2018
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