There is an unsaved comment in progress. You will lose your changes if you continue. Are you sure you want to reopen the work item?
A joint Italian and German Amphibious Assault of Malta plus an assisting Airborne Assault using German and Italian Airborne units seems to only need the one Italian SA. No German SA is used up.
I realize that rule 7.2 states "As part of the same Special Action expended, an airborne assault may also be mounted into the area if airborne units are in range." but rule 9.42 states "JOINT AXIS OPERATIONS: The Italian Special Action must always
be spent for any Axis amphibious invasion or retreat before combat which involves the Mediterranean fleet (only possible after Italy joins the war). A German Special Action must also be spent if any non-Italian Axis units participate."
So the rules may be conflicting but the Joint Axis Operation seems to dictate the use of a German Special Action if German units participate.