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		<title>MIDI Unlocks Over €60M From Tigné Point And Manoel Island Concession Ahead of €50M Bond Deadline</title>
		<link>https://www.amphora.media/2026/03/midi-manoel-island-tigne-point-concession-sales</link>
					<comments>https://www.amphora.media/2026/03/midi-manoel-island-tigne-point-concession-sales#respond</comments>
		
		<dc:creator><![CDATA[Julian]]></dc:creator>
		<pubDate>Fri, 20 Mar 2026 09:31:42 +0000</pubDate>
				<category><![CDATA[Investigations]]></category>
		<category><![CDATA[business]]></category>
		<category><![CDATA[malta]]></category>
		<category><![CDATA[manoel island]]></category>
		<category><![CDATA[midi]]></category>
		<category><![CDATA[tigne]]></category>
		<guid isPermaLink="false">https://www.amphora.media/?p=1997</guid>

					<description><![CDATA[MIDI plc has unlocked over €60 million in asset sales from its Manoel Island and Tigne Point concession in months — including a €47.3 million deal with the government— as it races to meet a €50 millionbond repayment deadline in July 2026.]]></description>
										<content:encoded><![CDATA[
<p><strong>MIDI plc has unlocked over €60 million in asset sales from its Manoel Island and Tigne Point concession in months — including a <a href="https://cdn.borzamalta.com.mt/download/announcements/MDI214.pdf">€47.3 million deal with the government</a>— ahead of a €50 million bond repayment deadline in July 2026.</strong></p>



<p>The transactions form part of a series of asset sales tied to the Tigné Point and Manoel Island concession to redeem a €50 million secured bond issued in June 2016.</p>



<p>Between December 2025 and February 2026, MIDI, entered into three promise of sale agreements worth more than €18 million on Tigne land to: </p>



<ul class="wp-block-list">
<li>A firm owned by <a href="https://cdn.borzamalta.com.mt/download/announcements/MDI211.pdf">Burak Başe</a>l, a Cypriot businessman in business with alleged Albanian organised crime figures (€10.2 million)</li>



<li>A Panamanian company owned by <a href="https://cdn.borzamalta.com.mt/download/announcements/MDI213.pdf">Zamir Magomedovich Abdullaev</a>(€5.5 million)</li>



<li>And another with Gozitan developer <a href="https://cdn.borzamalta.com.mt/download/announcements/MDI210.pdf">Joseph Portelli,</a> which has since been rescinded. (€2.5 million) </li>
</ul>



<p>The over €60 million unlocked in recent deals does not include proceeds from previous sales, such as the €20 million MIDI earned through the creation of Tigne Mall plc (which was later acquired by Hili Ventures) in 2013; and the sales of individual units developed under MIDI. The €2.5 million Portelli deal is not included.</p>



<p>Since 2020, MIDI has recorded a profit only once &#8211; in 2021. In its 2025 financial statements, MIDI describes the bond repayment as its “paramount priority”, outlining a strategy that relies on increased residential sales, further asset disposals, and “the reimbursement by Government of the carrying amount of the net assets attributable to the Manoel Island project.”</p>



<p>According to the <a href="https://rizzofarrugia.com/download/32336/?parent=32335">2016 prospectus</a>, the bond issue was mainly intended to raise funds to restructure debt and complete development works.</p>



<figure class="wp-block-image size-large"><img fetchpriority="high" decoding="async" width="800" height="600" src="https://www.amphora.media/wp-content/uploads/sites/3/2026/03/MANOEL-ISLAND-2-800x600.jpg" alt="" class="wp-image-2000" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2026/03/MANOEL-ISLAND-2-800x600.jpg 800w, https://www.amphora.media/wp-content/uploads/sites/3/2026/03/MANOEL-ISLAND-2-600x450.jpg 600w, https://www.amphora.media/wp-content/uploads/sites/3/2026/03/MANOEL-ISLAND-2-400x300.jpg 400w" sizes="(max-width: 800px) 100vw, 800px" /></figure>



<h1 class="wp-block-heading"><strong>The Concession:&nbsp;</strong></h1>



<p>MIDI acquired a 99-year lease of land at Tigne’ Point (108,420 m2) and Manoel Island (267,900 m2) for Lm 39,570,000, approx. €92 million, on 15th June 2000.</p>



<p><strong>Under the contract, the total value for Manoel Island stood at </strong><strong>Lm 21,320,000</strong><strong> (approx. €49 million)</strong><strong>. However, it should be noted that </strong><strong>Lm </strong><strong>15,275,000</strong><strong> (approx. €35 million) of that amount expressly covered the marina and its facilities, which remain operational and seemingly still under MIDI’s control.</strong></p>



<p><strong>As of June 2025, more than €40.2 million of that remained due to the government.</strong><strong> A significant portion of the original premium was also paid out through public and heritage works.</strong><strong> A MIDI spokesperson previously told </strong><a href="https://timesofmalta.com/article/factcheck-how-much-manoel-island-cost-midi.1110958"><strong>The Times of Malta</strong></a><strong> that “€34.4 million represents a credit in respect of infrastructural and restoration works”</strong>.</p>



<p><strong>In April 2020</strong><strong>, the PA approved the transfer of 8,000 m</strong><strong><sup>2</sup></strong><strong> of land from Manoel Island to Tigne Point</strong><strong>; calculations of ‘eligible floor area’</strong><strong> extended it to 8,956 m</strong><strong><sup>2</sup></strong><strong> before the PA approved the construction of a new 17-storey tower</strong><strong> on 9,160 m</strong><strong><sup>2</sup></strong><strong>.</strong></p>



<p>Although the underlying concession remains subject to obligations and ground rent payable to the Government, the contract expressly permits the transfer of individual buildings and units, provided that the proportional ground rent and obligations are passed on to the transferee.&nbsp;</p>



<p>What is being transferred in these deals is the remaining term of the 99-year emphyteusis, together with the proportionate annual ground rent and obligations attached to each parcel.</p>



<figure class="wp-block-image size-large"><img decoding="async" width="800" height="600" src="https://www.amphora.media/wp-content/uploads/sites/3/2026/03/tigne-point-manoel-island-concession-800x600.jpg" alt="" class="wp-image-2013" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2026/03/tigne-point-manoel-island-concession-800x600.jpg 800w, https://www.amphora.media/wp-content/uploads/sites/3/2026/03/tigne-point-manoel-island-concession-600x450.jpg 600w, https://www.amphora.media/wp-content/uploads/sites/3/2026/03/tigne-point-manoel-island-concession-400x300.jpg 400w" sizes="(max-width: 800px) 100vw, 800px" /></figure>



<h1 class="wp-block-heading"><strong>The Deals: Fort Tigne/Manoel Island, Başel, Abdullaev</strong></h1>



<h2 class="wp-block-heading"><strong><span style="text-decoration: underline">17th March 2026: Manoel Island &amp; Fort Tigne’ &#8211; Malta’s Government&nbsp;<br>Value: €47.3 million (net reimbursement of circa €43 million)&nbsp;</span></strong></h2>



<p><em>Now rescinded deal: 16th December 2025: Fort Tigne’ &#8211; Joseph Portelli&nbsp;</em><br><em>Value: €2,500,000</em></p>



<p><strong>On 17th March, the government and MIDI announced a €47.3 million deal to rescind the concessions on both Manoel Island and Fort Tigne.</strong></p>



<p>A few months prior, MIDI had entered into a promise of sale with J. Portelli Projects Ltd over Fort Tigne’ and its surrounding grounds, located at Tigne’ Point, for €2,500,000.</p>



<p>J. Portelli Projects Ltd is owned by Joseph Portelli, who planned to construct a hotel on the site.</p>



<p>Prime Minister Robert Abela had described the plans as “obscene” and made reference to the site in his <a href="https://www.gov.mt/en/Government/DOI/Press%20Releases/Pages/2025/12/31/PR252323en.aspx">New Year’s message</a>. The site now forms part of the €47.3 million deal, however, it is unclear on the distribution of value.</p>



<p>Joseph Portelli did not reply to Amphora Media’s questions about the deal.</p>



<figure class="wp-block-image size-large"><img decoding="async" width="800" height="600" src="https://www.amphora.media/wp-content/uploads/sites/3/2026/03/TIGNE-FOT-800x600.jpg" alt="" class="wp-image-2021" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2026/03/TIGNE-FOT-800x600.jpg 800w, https://www.amphora.media/wp-content/uploads/sites/3/2026/03/TIGNE-FOT-600x450.jpg 600w, https://www.amphora.media/wp-content/uploads/sites/3/2026/03/TIGNE-FOT-400x300.jpg 400w" sizes="(max-width: 800px) 100vw, 800px" /></figure>



<h2 class="wp-block-heading"><strong><span style="text-decoration: underline">19th December 2025: T3 unit at Tigne’ point &#8211; Basel Capital (owned by Burak Başel)<br>Value: €10,200,000</span></strong></h2>



<p>MIDI entered into promise of sale agreements with Basel Capital Limited, owned by Burak Başel, over eleven commercial premises which underlie the Pjazza Blocks as well as the building known as Unit T3, all situated at Tigne Point, for €10,200,000.</p>



<p>Başel has a diverse portfolio of companies, including fintechs, Finance Incorporated (owner of Paymix) and Corpayss. He also has companies that provide services for gambling businesses and operates several services within the gambling and betting industries.</p>



<p><strong>Amphora Media has previously reported how in Albania, Başel is the registered owner of Universe</strong><strong>, which lists “electronic distance gaming” among its activities and which he owns via Universal Software Solutions in Curacao.</strong></p>



<p><strong>The other owner is a company called MAREN</strong><strong>. MAREN was once owned by Ramazan Hasanbelli</strong><strong>, an Albanian citizen convicted in Italy for drug trafficking </strong><strong>and organised crime. The current co-owner is his brother, Ilir Hasanbelli, who continued the business with Başel after Ramazan’s conviction</strong><strong>.</strong></p>



<p><a href="https://www.amphora.media/2025/02/betting-on-billions-illegal-gambling-falyali-kebabfactory-foodforfit-owners">An investigation by OCCRP, Amphora Media, Times of Malta</a> and other global partners also revealed how Cemil Önal, a since murdered whistleblower, had alleged that Başel played a role within the gambling empire of Halil Falyalı &#8211; a politically connected Turkish Cypriot gambling mogul murdered in February 2022.</p>



<p>Başel has denied all connections to the case and said his encounters with Falyalı were limited to software purchase.</p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="800" height="600" src="https://www.amphora.media/wp-content/uploads/sites/3/2026/03/tigne-point-1-800x600.jpg" alt="" class="wp-image-2004" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2026/03/tigne-point-1-800x600.jpg 800w, https://www.amphora.media/wp-content/uploads/sites/3/2026/03/tigne-point-1-600x450.jpg 600w, https://www.amphora.media/wp-content/uploads/sites/3/2026/03/tigne-point-1-400x300.jpg 400w" sizes="auto, (max-width: 800px) 100vw, 800px" /></figure>



<h2 class="wp-block-heading"><strong><span style="text-decoration: underline">24th February 2026: T15 Building (Under Construction) &#8211; The 540 Hub LTD (UBO: Zamir Magomedovich Abdullaev)<br>Value: €5,500,000</span></strong></h2>



<p>Zamir Magomedovich Abdullaev is the registered beneficial owner of The 540 Hub Limited, a company that registered with the Malta Business Registry the same day it purchased the “T15 Building”, a building under construction at Tigne Point, for €5,500,000.</p>



<p>Abdullaev, a Russian-Maltese national who became a Maltese citizen in 2015, is the beneficial owner of The 540 Club Limited through a company based in Panama, Echelon Investments Limited, S.A.&nbsp;</p>



<p>Speaking to Amphora Media, Abdullaev said that the company “intends to develop a boutique commercial building — including shops, offices and cafeterias — within the permitted small size parameters.”</p>



<p><strong>He said that the final signing of the contract is subject to government approval.</strong></p>



<p>Abdullaev is also the owner of PNG (Overseas) Drilling &amp; Services Ltd.&nbsp;</p>



<p>Abdullaev said that the parent company, PNG DSL, was “established in the British Virgin Islands about 15–20 years ago as a holding structure to provide specialised upstream contractor oil services in the former USSR countries, the Middle East and North Africa.”</p>



<p>He said that “between 2008 and 2023, regional branches were set up to cover key markets: Russia — for operations in the former USSR; Malta — for North Africa; and Kuwait — for opportunities in the Gulf region.”</p>



<p>Abdullaev ended his directorship of BK PNG, or PNG Drilling company in Russia, in November 2022. Until 2024, the 99% shareholder was Anzhella Rabadanovna Abdullaeva, but ownership has been since transferred to Poisk Holding. Abdullaev explained that Poisk Holding “was set up by the management team and external investors to organise the management buyout”.&nbsp;</p>



<p>Abdullaev added that PNG DSL “took the decision to sell its assets in Russia and exit the market” following the conflict in Ukraine and subsequent sanctions imposed by the USA and EU in 2022. He stepped down as CEO of BK PNG in 2022 and the business was sold in stages during 2023–2024.</p>



<p>“The family have no involvement and or connection to the business anymore,” he added.</p>



<p>Abdullaev stressed that he has been a resident of Malta since 1991 and that it has been his home for many years.&nbsp;</p>



<p>Prior to the exit from Russia, BK PNG provided services to joint ventures involving Rosneft and its international partners from the USA and Europe. Abdullaev said that “at the time of engagement, these entities complied with applicable laws and were not subject to sanctions”.</p>



<p><strong>According to an industry association, BK PNG had a contract with</strong><strong> Gazpromneft-Orenburg LLC, </strong><a href="https://www.europarl.europa.eu/RegData/etudes/BRIE/2025/775863/EPRS_BRI(2025)775863_EN.pdf"><strong>part of the Russian state-owned gas monopoly Gazprom</strong></a><strong> at least until 2024</strong><strong>.&nbsp;</strong></p>



<p>Abdullaev explained that the former entity his business worked with is distinct from the state-owned monopoly. “Under family ownership, BK PNG did not work for Gazprom. PNG DSL’s decision to exit Russia was driven by a strategic assessment of business risks, including reputation considerations. The company prioritised alignment with its long‑term international strategy and global compliance standard,” Abdullaev said.</p>



<p>“Our current strategic focus is on Libya and the Gulf region,” he added.</p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="800" height="600" src="https://www.amphora.media/wp-content/uploads/sites/3/2026/03/TIGNE-POINT-2-1-800x600.jpg" alt="" class="wp-image-2020" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2026/03/TIGNE-POINT-2-1-800x600.jpg 800w, https://www.amphora.media/wp-content/uploads/sites/3/2026/03/TIGNE-POINT-2-1-600x450.jpg 600w, https://www.amphora.media/wp-content/uploads/sites/3/2026/03/TIGNE-POINT-2-1-400x300.jpg 400w" sizes="auto, (max-width: 800px) 100vw, 800px" /></figure>



<h1 class="wp-block-heading"><strong>Other sales from the Tigne Point Concession: The Shopping Mall</strong></h1>



<p>The recent transactions form part of an overarching sell-off of several assets in Tigne’ Point, most notably the shopping mall.&nbsp;</p>



<p>In December 2024, Marsamxett Properties Ltd, a company owned by Hili Ventures, completed its squeeze-out process of Tigné Mall plc.</p>



<p>Tigné Mall plc was set up in 2013 after MIDI plc, which designed and built The Point shopping mall, sold its entire shareholding in the venture. Those shares were purchased by a combination of institutional investors (Mapfre MSV Life p.l.c., HSBC and Bank of Valletta) and members of the public. MIDI received €20.9 million from the share offer.</p>



<p>The Hili subsidiary had acquired over 49.68% of the issued share capital by September 2024 over a span of 10 months.</p>



<p>The government did not reply to Amphora Media’s questions about approvals, notifications or oversight mechanisms when parcels or buildings forming part of the concession are transferred to third parties. It did not confirm whether it was notified about these deals and did not explain the due diligence process.</p>



<p><strong>MIDI, Burak Basel, Joseph Portelli and the Government of Malta did not respond to questions sent.</strong></p>
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		<title>FATTI: Are Manoel Island delays beyond MIDI&#8217;s control?</title>
		<link>https://www.amphora.media/2025/06/fatti-are-manoel-island-delays-beyond-midis-control</link>
					<comments>https://www.amphora.media/2025/06/fatti-are-manoel-island-delays-beyond-midis-control#comments</comments>
		
		<dc:creator><![CDATA[Daiva]]></dc:creator>
		<pubDate>Tue, 03 Jun 2025 05:24:33 +0000</pubDate>
				<category><![CDATA[Fact-Check]]></category>
		<category><![CDATA[concession]]></category>
		<category><![CDATA[development]]></category>
		<category><![CDATA[malta]]></category>
		<category><![CDATA[manoel island]]></category>
		<guid isPermaLink="false">https://www.amphora.media/?p=677</guid>

					<description><![CDATA[The concession granted to MIDI plc to develop Manoel Island is currently under the spotlight after activists collected over 29,000 signatures calling on the government to reclaim the island for the public.]]></description>
										<content:encoded><![CDATA[
<p>The concession granted to MIDI plc to develop Manoel Island is currently under the spotlight after activists collected over 29,000 signatures calling on the government to reclaim the island for the public.</p>



<p>Activists argue that MIDI, the developer, is bound by contractual obligations to ‘substantially’ complete the project by 2023, which it has failed to fulfil. MIDI has pushed back, insisting that the project is taking so long due to ‘unforeseen’ architectural finds on site, appeal processes, and “slow motion” planning.</p>



<p>Malta’s Prime Minister Robert Abela says the government’s hands are tied, and the developer would be eligible for hefty compensation if the concession was cancelled.</p>



<p>Opposition leader Bernard Grech believes the government must honour its obligations – but the interview did not cover developers&#8217; obligations&#8221;. In recent days, several Nationalist Party MPs have come out in favour of scrapping the deal. Even the Labour Party&#8217;s president admitted to having signed the petition.</p>



<p>So did MIDI do everything it could to fulfil its contractual obligations?</p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="1024" height="640" src="https://www.amphora.media/wp-content/uploads/sites/3/2025/05/claims-1024x640.jpg" alt="" class="wp-image-652" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2025/05/claims-1024x640.jpg 1024w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/claims-300x188.jpg 300w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/claims-768x480.jpg 768w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/claims-1536x960.jpg 1536w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/claims.jpg 1600w" sizes="auto, (max-width: 1024px) 100vw, 1024px" /></figure>



<p>In 2024, the Times of Malta fact-checked claims about whether the concession contract allows the government to reclaim Manoel Island if the developer fails to substantially complete the works.</p>



<p>In response, MIDI wrote that “The delays encountered are clearly documented and include the delays associated with the archaeological finds which necessitated the complete redesign of the masterplan, delays associated the approval of development permits and most recently the delay associated with the requirement to prepare a Heritage Impact Assessment, which is still ongoing.”</p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="1024" height="640" src="https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-1-1024x640.jpg" alt="Manoel Island Malta" class="wp-image-663" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-1-1024x640.jpg 1024w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-1-300x188.jpg 300w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-1-768x480.jpg 768w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-1-1536x960.jpg 1536w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-1.jpg 1600w" sizes="auto, (max-width: 1024px) 100vw, 1024px" /></figure>



<p>Speaking to MaltaToday, MIDI CEO Mark Portelli admitted that the 2023 deadline stipulated in the concession contract was breached. Still, he argued that the deed includes automatic provisions for extending that deadline, and those provisions cover building permits, archaeological finds, “any delays beyond the control of MIDI”.</p>



<p>He also specified that negotiations with the government are ongoing regarding the deadline extension based on the archaeological findings.</p>



<p style="font-style:normal;font-weight:800">Neither MIDI nor the government replied to our questions about the content and timeline of these negotiations.</p>



<p>Portelli considers that the company lost 10 years due to archaeological excavations on the two sites included in the concession. He expects 10 years to be added to the completion deadline.</p>



<p>“The Group has encountered several unforeseen delays related to the issuance of development permits and archaeological finds at both Manoel Island and Tigné Point. These issues, which were not foreseen at the time the emphyteutical deed was granted in 2000, entitles the Group to an extension of the completion date for the development works as per the provisions of the Deed,” MIDI’s chairman wrote in the company’s annual report.</p>



<p></p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="1024" height="640" src="https://www.amphora.media/wp-content/uploads/sites/3/2025/05/FACTS-1024x640.jpg" alt="" class="wp-image-648" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2025/05/FACTS-1024x640.jpg 1024w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/FACTS-300x188.jpg 300w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/FACTS-768x480.jpg 768w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/FACTS-1536x960.jpg 1536w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/FACTS.jpg 1600w" sizes="auto, (max-width: 1024px) 100vw, 1024px" /></figure>



<p>Signed in 2000, the concession agreement contains clauses that establish a 2023 deadline to ‘substantially’ complete the development, and fines in the event this is not done.&nbsp;</p>



<p>Fines also apply if the developer fails to complete the restoration of heritage buildings, such as the Lazzaretto, by specified deadlines and commence works to prevent further deterioration of the heritage sites within six months, with completion expected within two years. The Lazzaretto restoration is still a work in progress: MIDI&#8217;s website still refers to it in the future tense.</p>



<p>The contract also requires the developer to apply for all necessary permits and authorisations within 12 months. Data on the Planning Authority’s website shows that the first application on Manoel Island since the concession agreement was for the restoration of Fort Manoel in 2001.</p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="1024" height="640" src="https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island--1024x640.jpg" alt="Manoel Island Malta" class="wp-image-667" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island--1024x640.jpg 1024w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island--300x188.jpg 300w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island--768x480.jpg 768w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island--1536x960.jpg 1536w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-.jpg 1600w" sizes="auto, (max-width: 1024px) 100vw, 1024px" /></figure>



<p>Failures to observe obligations are subject to fines. Meanwhile, if completion delays persist for three years, the government can rescind the concession.</p>



<p>There is a clause stating that “neither party shall be liable for delay in performing or failure to perform obligations if the delay or failure results from any event or circumstance outside its control.”</p>



<p>However, it points to a schedule that lists such events and circumstances specifically, and the list includes wars, floods, riots, and trade disputes, but not permitting processes, legal action or red tape.</p>



<p>MIDI’s argument has been that the deadlines do not apply since the company qualifies for an extension. “The clock is on hold,” Portelli said in 2025. In an earlier interview, he said archaeological digs began in 2019 and will last nearly five years.</p>



<p>A letter from Mamo TCV, a law firm representing MIDI, submitted to the Planning Authority states that “even a (hypothetical) breach of the condition [completion deadline] [&#8230;] would not lead to ipso jure [by law] termination, but one which is at the discretion of the grantor [government]”.</p>



<p>It can be argued that archaeological finds are not as unforeseen as MIDI claims them to be. Attachments to the concession agreement include a report which mentions “many cemeteries on the island”.</p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="1024" height="640" src="https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-1024x640.jpg" alt="Manoel Island Malta" class="wp-image-670" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-1024x640.jpg 1024w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-300x188.jpg 300w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-768x480.jpg 768w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-1536x960.jpg 1536w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island.jpg 1600w" sizes="auto, (max-width: 1024px) 100vw, 1024px" /></figure>



<p style="font-style:normal;font-weight:800">Schedules attached to the contract allow the developer to address the discovery of archaeological remains by choosing to either rescind the concession over the affected areas, integrate the remains into the development if feasible, or—if the rest of the site becomes unsuitable—relinquish the entire concession. In such cases, the developer is entitled to a proportional refund and compensation for unusable improvements. A report by the Planning Authority shows that MIDI chose to integrate the cemeteries and convert them into a garden.</p>



<p>The fact that Manoel Island contains cemeteries has long been known. A <a href="https://www.um.edu.mt/library/oar/bitstream/123456789/40489/1/9-4-5-1987.pdf" data-type="link" data-id="https://www.um.edu.mt/library/oar/bitstream/123456789/40489/1/9-4-5-1987.pdf">1987 publication by Paul Cassar</a> stated that “There were six cemeteries, at different periods of time, associated with the lazzaretto”.</p>



<p>Planning Authority documents associated with MIDI’s 2017 development application clearly show that Superintendence for Cultural Heritage already flagged the likelihood of archaeological finds, as well as impact on Valletta’s UNESCO status.</p>



<p>Article 13 of the concession contract says that “the time limits&#8221; can be extended by any &#8220;such period&#8221; or &#8220;periods starting three months&#8221; from the date a required application is submitted, until the date that application is granted. This provision applies on condition that the developer duly filed all required applications and provided all the information required for them.</p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="1024" height="640" src="https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-2-1024x640.jpg" alt="Manoel Island Malta" class="wp-image-664" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-2-1024x640.jpg 1024w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-2-300x188.jpg 300w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-2-768x480.jpg 768w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-2-1536x960.jpg 1536w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/Manoel-Island-2.jpg 1600w" sizes="auto, (max-width: 1024px) 100vw, 1024px" /></figure>



<p>Some of the procedural delays were caused by the court questioning supporting documentation. An environmental impact assessment was challenged in court due to an alleged conflict of interest; however, in 2023, the court ruled that the assessment was acceptable. Nevertheless, the Superintendence for Cultural Heritage was not satisfied with the photomontages and archaeological evaluations.&nbsp;</p>



<p>The Environment &amp; Resources Authority also noted that a nature permit would be required. This shows that competent authorities repeatedly had to remind the developer of the standards required for this type of application.</p>



<p>The question whether the delays are justifiable is ambiguous: if the government considered that delays up to 2023 were unjustified, it could have imposed fines, but in response to questions by the Times of Malta in 2024, MIDI did not admit to paying any fines and the government’s spokesperson did not answer the question. Neither MIDI nor the government replied to our questions directly.</p>



<p>Neither the government nor MIDI clarified the stage the discussion on the delays is in. MIDI’s 2024 annual report mentions discussions with the government – something its CEO Mark Portelli also confirmed in his <a href="https://youtu.be/XcmJNFs2CPk?feature=shared&amp;t=626" data-type="link" data-id="https://youtu.be/XcmJNFs2CPk?feature=shared&amp;t=626">2025 interview</a>.</p>



<p></p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="1024" height="640" src="https://www.amphora.media/wp-content/uploads/sites/3/2025/05/VERDICT-1024x640.jpg" alt="" class="wp-image-647" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2025/05/VERDICT-1024x640.jpg 1024w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/VERDICT-300x188.jpg 300w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/VERDICT-768x480.jpg 768w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/VERDICT-1536x960.jpg 1536w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/VERDICT.jpg 1600w" sizes="auto, (max-width: 1024px) 100vw, 1024px" /></figure>



<p>The concession agreement contains several clauses that allow the government to ‘rescind’ (in full or in part) or ‘dissolve’ the concession contract. Regarding missed deadlines, there is currently no clarity from the government on its interpretation of whether project implementation delays are justified. Had the government imposed fines in 2023, it would be a clear signal. From MIDI’s responses to the media and the lack of mention of penalties in its annual report, it appears that no fines were imposed.</p>



<p>Since 2017, it was flagged to MIDI that cemeteries on site will require archaeological examinations, as cemeteries on the site have been mentioned in multiple sources. The impact of views and vistas of Valletta has also been flagged in late December in the planning application process. MIDI had the option to exclude sensitive areas from the concession, but did not use it.</p>



<p style="font-style:normal;font-weight:800">As pointed out by MIDI’s lawyers, the interpretation of how the deadlines should be honoured is up to the government. From the limited communication on the issue from the government, it appears that, as a contracting side, it has accepted the delays and did not challenge or fine MIDI.<br>Pending the government’s communication on its interpretation of the acceptability of the delays, the matter remains ambiguous.</p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="1024" height="640" src="https://www.amphora.media/wp-content/uploads/sites/3/2025/06/AMBIGUOUS-VERDICT-1024x640.jpg" alt="" class="wp-image-681" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2025/06/AMBIGUOUS-VERDICT-1024x640.jpg 1024w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/AMBIGUOUS-VERDICT-300x188.jpg 300w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/AMBIGUOUS-VERDICT-768x480.jpg 768w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/AMBIGUOUS-VERDICT-1536x960.jpg 1536w, https://www.amphora.media/wp-content/uploads/sites/3/2025/06/AMBIGUOUS-VERDICT.jpg 1600w" sizes="auto, (max-width: 1024px) 100vw, 1024px" /></figure>



<p><em>This project is supported by the European Media and Information Fund. The sole responsibility for any content supported by the European Media and Information Fund lies with the authors and it may not necessarily reflect the positions of the EMIF and the Fund Partners, the Calouste Gulbenkian Foundation and the European University Institute.</em></p>



<figure class="wp-block-image size-large"><img loading="lazy" decoding="async" width="847" height="1024" src="https://www.amphora.media/wp-content/uploads/sites/3/2025/05/EMIF_Main_logo_Black-847x1024.jpg" alt="" class="wp-image-631" srcset="https://www.amphora.media/wp-content/uploads/sites/3/2025/05/EMIF_Main_logo_Black-847x1024.jpg 847w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/EMIF_Main_logo_Black-248x300.jpg 248w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/EMIF_Main_logo_Black-768x929.jpg 768w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/EMIF_Main_logo_Black-1270x1536.jpg 1270w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/EMIF_Main_logo_Black-1694x2048.jpg 1694w, https://www.amphora.media/wp-content/uploads/sites/3/2025/05/EMIF_Main_logo_Black.jpg 1769w" sizes="auto, (max-width: 847px) 100vw, 847px" /></figure>
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