Double Tax Agreements in Malta

Double Tax Agreements in Malta

Malta has a large and growing network of double tax treaties – currently comprising double tax treaties in force. Malta’s tax treaties are largely inspired by the provisions of the OECD Model Tax Convention on Income and Capital – as updated at the time of negotiation. Malta companies accordingly enjoy extensive treaty protection from double taxation. Malta companies also benefit from domestic unilateral relief mechanisms and they are also, of course, entitled to the benefits of the European Union Tax Directives (including the Parent-Subsidiary Directive and the Interest & Royalties Directive) in view of Malta’s membership of the EU. The following is a list of Malta’s Double Tax Treaties in force, signed but not yet in force and currently being negotiated:

Double Tax Treaties – In Force

Country Flag Country Name Taxation Treaties In Force Legal Notice
albania Albania Double Taxation Relief (Taxes on Income) (Republic of Albania) – Signed on 2 May 2000 LN 122 of 2001
australia Australia Double Taxation Relief (Taxes on Income) (Australia) – Signed on 9 May 1984 LN 45 of 1985
austria Austria Double Taxation Relief (Taxes on Income) (Republic of Austria) Order 1981 – Signed on 29 May 1978 LN 130 of 1981
bahrain Bahrain Double Taxation Relief (Taxes on Income) (Kingdom of Bahrain) Order, 2012 – Signed on 12 April 2010 LN 82 of 2012
barbados Barbados Double Taxation Relief (Taxes on Income) (Barbados) Order, 2002 – Signed on 5 December 2001 LN 249 of 2002
Protocol between Malta and Barbados amending the convention between Malta and Barbados for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income signed at London on the 5th day of December 2001 – signed on 25th September 2013 LN 447 of 2013
Double Taxation Relief (Taxes on Income) (Barbados) (Amendment) Order, 2014  Commencement Notice LN 142 of 2014
belgium Belgium Double Taxation Relief (Taxes on Income) (Kingdom of Belgium) (Amendment) Order, 2002 – Signed on 28 June 1974 LN 108 of 1976
Double Taxation Relief (Taxes on Income) (Kingdom of Belgium) (Amendment) Order, 2002 – Supplemenatry Agreement Signed on 23 June 1993 LN 83 of 2003
bulgaria Bulgaria  Double Taxation Relief (Taxes on Income) (People’s Republic of Bulgaria) Order, 1988 – Signed on 23 July 1986 LN 62 of 1988
canada Canada  Double Taxation Relief (Taxes on Income) (Canada) Order, 1988 – Signed on 25 July 1986 LN 12 of 1988
china China  Double Taxation Relief (Taxes on Income) (People’s Republic of China) Order, 1994 – Signed on 2 February 1993 LN 104 of 1994
Double Taxation Relief (Taxes on Income) (People’s Republic of China) Order, 2011 – Signed on 23 October 2010 LN 423 of 2011
croatia Croatia  Double Taxation Relief (Taxes on Income) (Republic of Croatia) Order, 2000 – Signed on 21 October 1998 LN 71 of 2000
cyprus Cyprus  Double Taxation Relief (Taxes on Income) (Republic of Cyprus) Order, 1994 – Signed on 22 October 1993 LN 139 of 1994
czechrepublic Czech Republic Double Taxation Relief (Taxes on Income) (Czech Republic) Order, 1997 – Signed on 21 June 1996 LN 228 of 1997
denmark Denmark Double Taxation Relief (Taxes on Income) (Kingdom of Denmark) Order, 1999 – Signed on 13 July 1998 LN 124 of 1999
egypt Egypt Double Taxation Relief (Taxes on Income) (The Arab Republic of Egypt) Order, 2001 – Signed on 20 February 1999 LN 205/2001
estonia Estonia Double Taxation Relief (Taxes on Income) (The Republic of Estonia) Order, 2003 – Signed on 3 May 2001 LN 114 of 2003
finland Finland Double Taxation Relief (Taxes on Income) (Republic of Finland) Order, 1981 – Signed on 24 March 1975 LN 109 of 1981
Double Taxation Relief Income with the Republic of Finland Order, 2001 – Signed on 30 October 2000 LN 34 of 2002
france France Double Taxation Relief (Taxes on Income) (Republic of France) Order, 1983 – Signed on 25 July 1977 LN 5 of 1983
Double Taxation Relief (Taxes on Income) (Republic of France) (Amendment) Order, 1998 – Protocol Signed on 8 July 1994 LN 238 of 1998
Double Taxation Relief (Taxes on Income) (Republic of France) (Amendment) Order, 2008 – Protocol Signed on 29th August 2008. LN 329 of 2010
georgia Georgia Agreement between Malta and TheGovernment of Georgia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital – signed on 23 October 2009 LN 65 of 2010
germany Germany Double Taxation Relief (Taxes on Income) (Federal Republic of Germany) Order, 2002 – Signed on 8 March 2001 LN 254 of 2002
Double Taxation Relief on Taxes on Income withthe Federal Republic of Germany (Amendment) Order, 2011, Signed on 17 June 2010 LN 383 of 2011
greece Greece Double Taxation Relief (Taxes on Income) (Hellenic Republic) Order, 2008 – Signed on 13 October 2006 LN 268 of 2008
guernsey Guernsey Double Taxation Relief (Taxes on Income) (The States of Guernsey) Order, 2013 – Signed on 12 March 2012 LN 117 of 2013
Hong-Kong Hong Kong  Double Taxation Relief (Taxes on Income) (The Hong Kong Special Administrative Region of the People’s Republic of China) Order, 2012 – Signed on 8 November 2011 LN 321 of 2012
hungary Hungary Double Taxation Relief (Taxes on Income) (Republic of Hungary) Order, 1994 – Signed on 6 August 1991 LN 75 of 1994
iceland Iceland Double Taxation Relief (Taxes on Income) (Iceland) Order, 2006 – Signed on 23 September 2004 LN 261 of 2006
india India Double Taxation Relief (Taxes on Income) (Republic of India) Order, 1995 – Signed on 28 September 1994 LN 46 of 1995
Agreement between the Government of Malta and the Government of the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income – signed on 8 April 2013 LN 448 of 2013
Double Taxation Relief (Taxes on Income) (Republic of India) Order, 2014 – Commencement Notice LN 67 of 2014
ireland Ireland Convention between Malta and Ireland for the avoidance of Double Taxation and the Prevention of Fiscal evasion with respect to taxes on income – Signed 14 November 2008 LN 62 of 2009
isle-of-man Isle of Man Double Taxation Relief (Taxes on Income) (The Isle of Man) Order – signed on 23 Octber 2009 LN 162 of 2010
Israel Israel Convention between the Government of Malta and the Government of the State of Israel for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income – signed on 28 July 2011 LN 343 of 2013
Double Taxation Relief (Taxes on Income) (The State of Israel) Order, 2013 – Commencement Notice LN 57 of 2014
italy Italy  Double Taxation Relief, (Taxes on Income) (Republic of Italy)Order, 1986 – Signed on 16 July 1981 LN. 31 of 1986
Double Taxation Relief, (Taxes on Income) (Republic of Italy) (Amendment) Order, 2011 signed on 13 March 2009 LN 14 of 2011
jersey Jersey Double Taxation Relief (Taxes on Income) (Jersey) Order, 2010 – Signed on 25 January 2010 LN 432 of 2010
jordan Jordan Double Taxation Relief (Taxes on Income) (The Hashemite Kingdom of Jordan) Order, 2010 – Signed on 16 April 2009 LN 501 of 2010
korea Korea Double Taxation Relief (Taxes on Income) (Republic of Korea) Order, 1999 – Signed on 25 March 1997 LN 18 of 1999
kuwait Kuwait Double Taxation Relief (Taxes on Income) (State of Kuwait) Order, 2004 – Signed on 24 July 2002 LN 349 of 2004
latvia Latvia Double Taxation Relief (Taxes on Income) (Republic of Latvia) Order, 2001 – Signed on 22 May 2000 LN 89 of 2001
lebanon Lebanon Double Taxation Relief (Taxes on Income) (Republic of Lebanon) Order, 2000 – Signed on 23 February 1999 LN 119 of 2000
Protocol amending the convention between Malta and the Republic ofLebanon with respect to taxes on income- signed on 16 April 2010 LN 242 of 2010
libya Libya Double Taxation Relief (Taxes on Income) (Libyan Arab Republic) Order, 1973 – Signed on 5 October 1972 – Shall cease to have effect with respect to income derived during the taxable years beginning on or after 1 January 2011 LN 7 of 1973
Double Taxation Relief (Taxes on Income) (Libyan Arab Republic) (Amendment) Order, 1996 – Protocol Signed on 28 April 1995 LN 201 of 1996
Double Taxation Relief (Taxes on Income) (The Great Socialist People’s Libyan Arab Jamahiriya) Order, 2010 – Signed on 28th December 2008 – Shall have effect with respect to income derived during the taxable years beginning on or after 1 January 2011 LN 328 of 2010
Liechtenstein Liechtenstein Convention between the  Government of the Republic of Malta and the Government of the Principality of Liechtenstein for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital – signed on 27 September 2013 LN 65 of 2014
Entry into Force of the Convention between the Government of the Republic of Malta and the Government of the Principality of Liechtenstein for the Avoidance of Double Taxation and the Prevention of FiscalEvasion with respect to Taxes on Income and on Capital LN 259 of 2014
lithuania Lithuania Double Taxation Relief (Taxes on Income) (Republic of Lithuania) Order, 2004 – Signed on 17 May 2001 LN 337 of 2004
luxembourg Luxembourg Double Taxation Relief (Taxes on Income) (Grand Duchy of Luxembourg) Order, 1996 – Signed on 29 April 1994 LN 65 of 1996
Double Taxation Relief (Taxes on Income) (Grand Duchy of Luxembourg) (Amendment) Order, 2013 – Signed on 30 November 2011 LN 238 of 2013
Double Taxation Relief (Taxes on Income) (Grand Duchy of Luxembourg) (Amendment) Order, 2013 (L.N 238 of 2013) – Commencement Notice LN 275 of 2013
malaysia Malaysia Double Taxation Relief (Taxes on Income) (Malaysia) Order, 1986 – Signed on 3 October 1995 LN 281 of 2002
mauritius Mauritius  Double Taxation Relief (Taxes on Income) (The Republic of Mauritius) Order, 2014 – Signed on 15 October 2014 LN 409 of 2014
 Double Taxation Relief (Taxes on Income) (The Republic of Mauritius) Order, 2015 (L.N. 409 of 2014) – Commencement Notice   LN 362 of 2015
mexico Mexico Convention between the United Mexican States and Malta for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income – signed on 17 December 2012 LN 239 of 2013
Double Taxation Relief (Taxes on Income) (The United Mexican States) Order, 2014 – Commencement Notice L.N. 332 of 2014
moldova Moldova  Convention between the Government of The Republic of Malta and the Government of the Republic of Moldova for the avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Tax on Income – signed on 10 April 2014 LN 151 of 2014
Double Taxation Relief (Taxes on Income) (The Republic of Moldova) Order, 2015 Commencement Notice L.N. 228 of 2015
Montenegro Montenegro Convention between Malta and Montenegro for the avoidance of Double Taxation with respect to taxes on income – Signed 4 November 2008 LN 343 of 2009
morocco Morocco Double Taxation Relief Taxes on Income with the Kingdom of Marocco Order, 2007 – Signed 26  October 2001 LN 189 of 2007
netherlands Netherlands Double Taxation Relief (Taxes on Income) (Kingdom of the Netherlands) Order, 1980 – Signed on 18 May 1977 LN 90 of 1980
Double Taxation Relief (Taxes on Income) (Kingdom of the Netherlands) (Amendment) Order, 1999 – Protocol Signed on 18 July 1995 LN 146 of 1999
norway Norway Double Taxation Relief (Taxes on Income) (Kingdom of Norway) Order, 1979 – Signed on 2 June 1975 LN 35 of 1979
Double Taxation Relief (Taxes on Income) (The Kingdom of Norway) Order, 2013 – signed on 30 March 2012 LN 118 of 2013
pakistan Pakistan Double Taxation Relief (Taxes on Income) (Islamic Republic of Pakistan) Order, 1980 – Signed on 8 October 1975 LN 54 of 1980
poland Poland Double Taxation Relief (Taxes on Income) (Republic of Poland) Order, 1995 – Signed on 7 January 1994 LN 28 of 1995
Double Taxation Relief (Taxes on Income) (Republic of Poland)(Amendment) Order, 2012 – Signed on 6 April 2011 LN 14 of 2012
portugal Portugal Double Taxation Relief (Taxes on Income) (Portuguese Republic) Order, 2002 – Signed on 26 January 2001 LN 105 of 2002
qatar Qatar Agreement between Malta and The State of Qatar for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income Avoidance – signed on 26 August 2009 LN 69 of 2010
romania Romania Double Taxation Relief (Taxes on Income) (Romania) Order, 1997 – Signed on 30 November 1995 LN 65 of 1997
russia Russia Double Taxation Relief (Taxes on Income) (Russian Federation) Order, 2013 – signed on the 23 April 2013 LN 159 of 2013
Double Taxation Relief (Taxes on Income) (Russian Federation) Order, 2013 – Commencement Notice LN 150 of 2014
sanmarino San Marino Double Taxation Relief (Taxes on Income) (The Republic of San Marino) Order, 2006 – Signed on 3 May 2005 LN 270 of 2006
Protocol amending the convention between Malta and the Republic of San Marino with respect to taxes on income – signed on 10 September 2009 LN 192 of 2010
saudi-arabia Saudi Arabia Convention between the Government of Malta and the Government of the Kingdom of Saudi Arabia for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income – signed on 4 January 2012 LN 25 of 2013
serbia Serbia  Double Taxation Relief (Taxes on Income) (The Republic of Serbia) – Signed on 9 September 2009 LN 431 of 2010
singapore Singapore Double Taxation Relief (Taxes on Income) (Republic of Singapore) Order, 2008 – Signed on 29 February 2008 LN 194 of 2008
Double Taxation Relief (Taxes on Income) (Republic of Singapore) (Amendment) Order, 2013 – Signed on 20 November 2009 LN 257 of 2013
slovakia Slovakia Double Taxation Relief (Taxes on Income) (Slovak Republic) Order, 2001 – Signed on 7 September 1999 LN 1 of 2001
slovenia Slovenia Double Taxation Relief (Taxes on Income) (The Republic of Slovenia) Order, 2003 – Signed on 8 October 2002 LN 145 of 2003
southafrica South Africa Double Taxation Relief (Taxes on Income) (South Africa) Order, 1998 – Signed on 16 May 1997 LN 89 of 1998
Double Taxation Relief (Taxes on Income) (South Africa) (Amendment) Order, Signed on 24 August 2012 LN 392 of 2013
Double Taxation Relief (Taxes on Income) (South Africa) (Amendment) Order 2014 – Commencement Notice LN 3 of 2014
spain Spain Double Taxation Relief on Taxes on Income with the Kingdom of Spain Order, 2006 – Signed on 8 November 2005 LN 234 of 2006
sweden Sweden Double Taxation Relief (Taxes on Income) (The Kingdom of Sweden) Order, 1996 – Signed on 9 October 1995 LN 104 of 1996
switzerland Switzerland Double Taxation Relief (Ships and Aircraft) (Swiss Federation) Order, 1988 – Signed on 30 March 1987 LN 31 of 1988
Double Taxation Relief (Taxes on Income) (The Swiss Confederation) Order, 2012 – Signed 25 February 2011 LN 322 of 2012
syria Syria Convention between Malta and The Syrian Arab Republic for the avoidance of Double Taxation and the Prevention of Fiscal evasion with respect to taxes on income – Signed on 22 February 1999 LN 246 of 2001
tunisia Tunisia Convention between Malta and Tunisia for the avoidance of Double Taxation and the Prevention of Fiscal evasion with respect to taxes on income – Signed on 31 May 2000 LN 225 of 2002
turkey Turkey  Double Taxation Relief (Taxes on Income) (The Republic of Turkey) Order, 2013 – signed on 14 July 2011 LN 160 of 2013
Double Taxation Relief (Taxes on Income) (The Republic of Turkey) Order, 2013 (LN 160 of 2013) – Commencement Notice LN 177 of 2013
uae United Arab Emirates Double Taxation Relief (Taxes on Income) (United Arab Emirates) Order, 2009 – Signed on 13 March 2006 LN 99 of 2009
uk United Kingdom Double Taxation Relief (Taxes on Income) (United Kingdom of Great Britain and Northern Ireland) Order, 1995 – Signed on 12 May 1994 LN 105 of 1995
usa United States of America Double Taxation Relief (Ships and Aircraft) (United States of America) Order, 1997 – Signed on 11 March 1997 (Ships and Aircraft) LN 230 of 1997
Double Taxation Relief (Taxes on Income) (United States of America) Order, 2010 – Signed on 8 August 2008 LN 560 of 2010
uruguay Uruguay Double Taxation Relief (Taxes on Income) (The Oriental Republic of Uruguay) Order, 2013 – signed on 11 March 2011 LN 119 of 2013

 

Double Tax Treaties – Not In Force

Country Flag Country Name Treaties Signed But Not In Force 
belgium Belgium Protocol amending the agreement between the State of Malta and the Kingdom of Belgium for the avoidance of double taxation and the prevention of fiscal evasion,and the protocol signed at Brussels on 28 June 1974, as amended by the supplementary agreement signed at Bruseels on 23 June 1993 – signed on 19 January 2010 – (LN 274 of 2013)
Curaçao Curaçao Convention between the Republic Of Malta and the Kingdom Of The Netherlands, in  Respect of Curaçao, for the Avoidance Of Double Taxation and The Prevention of Fiscal Evasion With Respect To Taxes On Income signed on 18 November 2015
ukraine Ukraine Convention between the Government of Ukraine and the Government of the Republic of Malta for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income – signed on 4 September 2013

Tax Information Exchange Agreements – In Force

Country Flag Country Name Tax Information Exchange Agreements – In Force Legal Notice
 bahamas Bahamas Agreement between the Government of Malta and the Government of the Commonwealth of the Bahamas for the exchange of information relating to tax matters – signed on 18 January 2012 LN 26 of 2013
 bermuda Bermuda Exchange of Information (Tax Matters) (Bermuda) Order, 2013 – signed on 24 November 2011 LN 120 of 2013
 cayman-islands Cayman Islands Agreement between the Government of the Republic of Malta and the Government of the Cayman Islands for the Exchange of Information relating to tax matters – signed on 25 November 2013 LN 56 of 2014
Exchange of Information (Tax Matters) (Cayman Islands) Order, 2014 (L.N. 56 of 2014)  LN 143 of 2014
 gibraltar Gibraltar Agreement between the Government of Malta and the Government of Gibraltar for the exchange of information relating to tax matters – signed on 24 January 2012 LN 208 of 2012
 usa United States of America  Exchange of Information (United States of America) (FATCA) Order, 2014 – Signed on 13 December 2013   LN 78 of 2014
Exchange of Information (United States of America) (FATCA) Order, 2014 – Commencement Notice LN 290 of 2014
Exchange of Information (United States of America) (FATCA) (Amendment) Order, 2015 LN 30 of 2015

 

Tax Information Exchange Agreements – Signed But Not In Force

Country Flag Country Name Tax Information Exchange Agreements – Signed But Not In Force
macau Macao Agreement between the Government of Malta and the Government of the Macao Special Administrative Region of the People’s Republic of China concerning the exchange of information on tax matters – signed on 30 May 2013 – (LN 449 of 2013)
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