Double Taxation Treaties

Successive Maltese governments have sought to conclude double tax treaties with important trading partners as well as with emerging countries, in order to encourage the growth of international trade including that of financial services. To date, treaties are in force with over 65 countries and this policy is expected to continue in the future.

Most of Malta’s double tax treaties are based on the OECD model. Once concluded, a tax treaty becomes law by Ministerial order and overrides any provisions to the contrary under Maltese domestic tax legislation. Double taxation relief is available in the terms of the relative tax treaty. For more information on Malta's double tax treaties see below.

The following is an updated list of all Malta Double Tax Treaties.

Signed and Ratified

Albania Double Tax Treaty Malta - Albania : Signed on 2 May 2000
Australia Double Tax Treaty Malta - Australia : Signed on 9 May 1984
Austria Double Tax Treaty Malta - Austria : Signed on 29 May 1978
Bahrain Double Tax Treaty Malta - Bahrain : Signed on 12 April 2010
Barbados Double Tax Treaty Malta - Barbados : Signed on 5 December 2001
Barbados 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
Barbados Double Taxation Relief (Taxes on Income) (Barbados) (Amendment) Order, 2014 Commencement Notice
Belgium Double Tax Treaty Malta - Belgium : Signed on 28 June 1974
Belgium Supplementary Agreement Malta - Belgium : Signed on 23 June 1993
Bulgaria Double Tax Treaty Malta - Bulgaria : Signed on 23 July 1986
Canada Double Tax Treaty Malta - Canada : Signed on 25 July 1986
China Double Tax Treaty Malta - China : Signed on 2 February 1993
China Order 2011 : Signed in October 2010
Croatia Double Tax Treaty Malta - Croatia : Signed on 21 October 1998
Cyprus Double Tax Treaty Malta - Cyprus : Signed on 22 October 1993
Czech Republic Double Tax Treaty Malta - Czech Republic : Signed on 21 June 1996
Denmark Double Tax Treaty Malta - Denmark : Signed on 30 December 1998
Egypt Double Tax Treaty Malta - Egypt : Signed on 20 February 1999
Estonia Double Tax Treaty Malta - Estonia : Signed on 3 May 2001
Finland Double Tax Treaty Malta - Finland : Signed on 24 March 1975
Finland (Amendment) Signed on 30 October 2000
France Double Tax Treaty Malta - France : Signed on 5 July 1977
France (Amendment) Signed on 8 July 1994
France (Amendment) Signed on 29 August 2008
Georgia Double Tax Treaty Malta - Georgia : Signed on 23 October 2009
Germany Double Tax Treaty Malta - Germany : Signed on 8 March 2001

Germany Order 2012 : Signed in June 2010
Greece Double Tax Treaty Malta - Greece : Signed on 13 October 2006
Guernsey Double Tax Treaty Malta - Guernsey : Signed on 12 March 2012
Hong Kong Double Tax Treaty Malta - Hong Kong : Signed on 8 November 2011
Hungary Double Tax Treaty Malta - Hungary : Signed on 6 August 1991
Iceland Double Tax Treaty Malta - Iceland : Signed on 23 September 2004
India Double Tax Treaty Malta - India : Signed on 8 September 1994
India 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
India Double Taxation Relief (Taxes on Income) (Republic of India) Order, 2014 - Commencement Notice
Ireland Double Tax Treaty Malta - Ireland : Signed 14 November 2008
Isle of Man Double Tax Treaty Malta - Isle of Man : Signed 23 October 2009
Israel Double Tax Treaty Malta - Israel : Signed on 28 July 2011
Israel Double Taxation Relief (Taxes on Income) (The State of Israel) Order, 2013 - Commencement Notice
Italy Double Tax Treaty Malta - Italy : Signed on 16 July 1981
Italy Amendment, Order 2011: Signed on 13 March 2009
Jersey Double Tax Treaty Malta - Jersey : Signed on 25 January 2010
Jordan Double Tax Treaty Malta - Jordan : Signed on 16 April 2009
Korea Double Tax Treaty Malta - Korea : Signed on 25 March 1997
Kuwait Double Tax Treaty Malta - Kuwait : Signed on 24 July 2002
Latvia Double Tax Treaty Malta - Latvia : Signed on 22 May 2000
Lebanon Double Tax Treaty Malta - Lebanon : Signed on 23 February 1999
Lebanon (Amendment) Signed on 16 April 2010

Libya Double Tax Treaty Malta - Libya : Signed on 5 October 1972
Libya (Amendment) Signed on 28 April 1995
Libya (Has effect with respect to income derived during the taxable years beginning on or after 1 January 2011) 
Signed on 28 December 2008
Liechtenstein Convention - Signed on 27 September 2013
Liechtenstein Entry into Force of the Convention - LN 259 of 2014
Lithuania Double Tax Treaty Malta - Lithuania : Signed on 17 May 2001
Luxembourg Double Tax Treaty Malta - Luxembourg : Signed on 29 April 1994
Luxembourg (Amendment) Order 2013 - LN 238 of 2013 : Signed on 30 November 2011
Luxembourg (Amendment) Order 2013 - LN 275 of 2013 - Commencement Notice
Malaysia Double Tax Treaty Malta - Malaysia : Signed on 3 October 1995
Mexico Convention : Signed on 17 December 2012
Mexico Commencement Notice - 2014
Montenegro Double Tax Treaty Malta - Montenegro : Signed on 4 November 2008
Morocco Double Tax Treaty Malta - Morocco : Signed on 26 October 2001
Netherlands Double Tax Treaty Malta - Netherlands : Signed on 18 May 1977
Netherlands (Amendment) Signed on 18 July 1995
Norway Double Tax Treaty Malta - Norway : Signed on 2 June 1975
Norway Signed on 30 March 2012
Pakistan Double Tax Treaty Malta - Pakistan : Signed on 8 October 1975
Poland Double Tax Treaty Malta - Poland : Signed on 7 January 1994
 Poland Order 2012, signed in April 2011
Portugal Double Tax Treaty Malta - Portugal : Signed on 26 January 2001
Qatar Double Tax Treaty Malta - Qatar : Signed on 26 August 2009
Russia Double Tax Treaty Malta - Russia : Signed on the 23 April 2013
Russia Commencement Notice
Romania Double Tax Treaty Malta - Romania : Signed on 30 November 1995
San Marino Double Tax Treaty Malta - San Marino : Signed on 3 May 2005
San Marino (Amendment) Signed on 10 September 2009
Saudi Arabia  Convention for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income : Signed on 4 January 2012
Serbia Double Tax Treaty Malta - Serbia : Signed on 9 September 2009
Singapore Double Tax Treaty Malta - Singapore : Signed on 29 February 2008
Singapore Double Taxation Relief (Taxes on Income) (Amendment) Order, 2013 : Signed on 20 November 2009
Slovakia Double Tax Treaty Malta - Slovakia : Signed on 7 September 1999

Slovenia Double Tax Treaty Malta - Slovenia : Signed on 8 October 2002
South Africa Double Tax Treaty Malta - South Africa : Signed on 16 May 1997
South Africa Double Taxation Relief (Taxes on Income) (South Africa) (Amendment) Order : Signed on 24 August 2012
South Africa Double Taxation Relief (Taxes on Income) (South Africa) (Amendment) Order 2014 - Commencement Notice
Spain Double Tax Treaty Malta - Spain : Signed on 8 November 2005
Sweden Double Tax Treaty Malta - Sweden : Signed on 9 October 1995
Switzerland Double Taxation Relief (Ships and Aircraft) (Swiss Federation) Order, 1988 - Signed on 30 March 1987
Switzerland Double Taxation Relief (Taxes on Income) (The Swiss Confederation) Order, 2012 - Signed on 25 February 2011
Syria Double Tax Treaty Malta - Syria : Signed on 22 February 1999
Tunisia Double Tax Treaty Malta - Tunisia : Signed on 31 May 2000
Turkey Double Tax Treaty Malta - Turkey : Signed on 14 July 2011
Turkey Double Taxation Relief (Taxes on Income) (The Republic of Turkey) Order, 2013 (LN 160 of 2013) - Commencement Notice
UAE Double Tax Treaty Malta - United Arab Emirates : Signed on 13 March 2006
United Kingdom Double Tax Treaty Malta - United Kingdom : Signed on 12 May 1994
United States of America Signed on 11 March 1997 (Ships & Aircraft)
United States of America Signed on 8 August 2008 (Double Taxation Relief Order)
Uruguay Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital - Signed on 11 March 2011

Treaties Signed but not in Force

Mauritius
Moldova
Belgium
Ukraine

Tax Information Exchange Agreements – in Force

Bahamas
Bermuda
Gibraltar
Cayman Islands
Cayman Islands
United States of America
United States of America

Tax Information Exchange Agreements – Signed but not in Force

Macao

Honorary Consuls

An updated list of all Maltese Consular Representations Overseas is available here

About Malta's Double Taxation Treaties

Taxpayers satisfying the relevant conditions are entitled to double tax relief on income arising outside of Malta that is included in their taxable income.

Relief is granted in the form of a credit. In the absence of the tax treaty, double taxation relief is still available under the unilateral relief provisions for foreign tax incurred on income arising outside of Malta.

Companies may, subject to certain conditions, claim double taxation relief under the flat rate foreign tax credit instead of other forms of double tax relief. This may be especially beneficial in those cases where the foreign income has been exempt from tax or taxed at a reduced rate.

Withholding taxes

The normal treaty rate on dividends paid by Maltese companies is the company tax rate of 35%. Malta operates a full imputation system on the dividends paid, which means that the shareholder is eligible to a credit in respect of the tax paid by the company. As a result company profits are taxed only once and no further tax is payable by the shareholder on distributions.

Under Maltese law dividends paid to non-residents are not subject to withholding tax. Interest and royalties paid to non-residents are exempt from tax in Malta if they are not effectively connected with a permanent establishment in Malta through which the non-residents engage in a trade or business. As a result of these rules, the withholding tax on dividends, interest and royalties paid to residents of treaty and non-treaty countries is 0%.

No tax is payable by non-residents on capital gains tax arising on transfers of company shares or securities except where such gains result from the transfer of shares and securities of companies whose assets consist primarily of immovable property situated in Malta.

Membership Directory

Browse Directory
featured

WH Partners

WH Partners is a multi-disciplinary law firm with particular expertise in gaming and gambling, and the ICT and digital...
View profile