Malta s Double Tax Treaties

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1 Malta s Double Tax Treaties November 216

2 In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax treaties with important trading partners as well as with emerging countries. This policy is expected to continue in the future. To date, treaties are in force with 73 countries. The following table illustrates the treaty and non-treaty withholding tax rates when dividends, interest and royalties are paid from treaty countries to Maltese residents. In general there is no withholding tax under Maltese law on dividends, interest and royalties even where a treaty allows such tax. rates quoted in the table below do not take into account provisions of European Union Law which may be applicable. Country Dividends Interest Royalties Minority Majority Required for Majority Rates Rates Albania Australia 1 1 /3 a Austria /1 A 2 Azerbaijan* /8 T Bahrain Barbados 1 /1/2 b 1 / A 1 Belgium /1 B 27 /1 A 27 Bulgaria Canada /2 c /1 C 2 China D 1 Croatia Cyprus /1 d Curacao* 1 Czech Republic Denmark 1 2 E 1/27 k 2 Egypt 1 1 /1 v Estonia Page 2

3 Country Dividends Interest Royalties Minority Majority Required for Majority Rates Rates Finland France /1 Georgia Germany /26.38 Greece Guernsey Hong Kong Hungary 1 Iceland 1 India 2 A e Ireland /2f Isle of Man Israel 1 1 2/3 Italy /1 Jersey Jordan 1 1 /1o Korea /1 2 2 Kuwait /1 1 Latvia Lebanon 1 /1m 7. Libya 1 1 Liechtenstein Lithuania Luxembourg Malaysia / Mauritius 1 1 Mexico 1 //1 1/1/21/3/4t 1 /2/3/4u Moldova 6 12 Montenegro /1 Morocco Netherlands /1A Norway 1 1K 2 Pakistan /1G 1 Poland 1 1K Portugal 1 1 2E Qatar 7 Romania Russia ,1,2q 2 San Marino Saudi Arabia /7L 1 h j g / l /26. F H I S s 26. G 22.i 12 J 9 Page 3

4 Country Dividends Interest Royalties Minority Majority Required for Majority Rates Rates Serbia /1 J 2 Singapore - - 7/1 M Slovakia Slovenia South Africa /1 F Spain Sweden Switzerland 1 1 N 3 /1 O /3/3 o Syria Turkey p 1 2 Tunisia UAE UK Uruguay 1 L 2 P 7 1 3//12 q /1 Q 12 USA /1 R /3 1 3 Vietnam* 1 / v /1 T /1/1 U /1 v Treaties signed but not yet in force Andorra, Ukraine and protocol to the treaty with Belgium. Treaties being (re)negotiated Bosnia and Herzegovina, Kosovo, Oman and Thailand. Treaty A. for the use of, or right to use copyrights of literary, artistic or scientific work B. for interest on commercial debt-claims C. for the production or reproduction of literary, educational, dramatic, muscial or artistic work D. Tax on royalties derived as a consideration for the use of, or right to use, industrial, commercial, or scientific equipment shall not exceed 1 on an amount E. F. G. H. I. J. K. L. M. N. Corresponding to 7 of the gross amount of the royalties Held for a 12 month period prior to the date the dividends are declared applies to interest paid by the Government of that Contracting State, a political subdivision, a local authority or the Central Bank thereof and interest paid to a resident of the other Contracting State on corporate bonds traded on a Stock Exchange in the firstmentioned State. for the use of or right to use, any copyright of literary, artistic or scientific work, cinematographic films or tapes for television or broadcasting for interest paid in connection with the sale on credit of any industrial, commercial or scientific equipment or paid in connection with the sale on credit of any merchandise by one enterprise to another The rate applies to interest paid on loans as defined in the Malaysian Income Tax Act applies to the use of or, the right to use copyright of literary, artistic or scientific work including cinematograph films or films or tapes used for radio or television broadcasting Held for an uninterrupted period of 24 months. This period can also be met after the payment of dividends is made applies to royalties paid for the use of or the right to use, industrial, commercial or scientific equipment 7 applies if the interest is received by a bank, 1 in all other cases Page 4

5 O. P. Q. R. S. T. U. V. W. X. Held for an uninterrupted period of 24 months. This period can also be met after the payment of dividends is made applies to royalties paid for the use of or the right to use, industrial, commercial or scientific equipment 7 applies if the interest is received by a bank, 1 in all other cases Held for at least 12 months and provided both companies: are subject to and not exempted from tax; are not resident for tax purposes in a third state under any double taxation agreement; and have adopted the form of a limited liability company. applies to interest paid between associated companies and to interest paid in connection with the sale on credit of any industrial, commercial or scientific equipment; in connection with the sale of any merchandise by one enterprise to another enterprise; or on any loan of whatever kind granted by a bank Lower rate of also applies if the beneficial owner is a Collective Investment Scheme for the use of or the right to use, any industrial, commercial or scientific equipment, and copyright of literary, artistic or scientific work 1 applies to interest that does not quality as portfolio interest applies in four given scenarios, applies to interest from loans granted by certain banks, 1 applies in all other cases Interest arising in a Contracting State shall be exempt from tax in that State if paid: (a) to the Government of the other Contracting State/Central Bank thereof in relation to any loan, debt-claim or credit granted by any such bodies; g. h. i. j. k. l. m. n. o. p. q. 2 applies where the shareholding is less than 1 and where the payor is a company resident in Israel whose shares are listed and traded on a stock exchange. 3 applies where the shareholding is equal to or more than 1. A final dividend distribution tax is payable by the dividend-paying company at 1 Royalties paid to non-resident companies are subject to a withholding tax of 3 on 7 of the gross royalty i.e. resulting in a final tax of applies to dividends distributed by fund managers, investment custodians and corporate bodies. 1 if less than 1 holding and exchange of information; 27 in other cases. generally and an interest from convertible bonds, profit-sharing bonds and participation bans amongst others The rate applies to interest on debts, deposits and guarantees 1 applies when distributed by mining, telecommunications, insurance, re-insurance and financial companies and banks for film copyright royalties 3 applies to interest paid by financial institutions out of deposits in domestic currency or indexed units with more than a 1-year term, interest on bonds with a term of more than 3 years issued through a public offer and quoted on the stock exchange and on income certificates issued by financial trusts through public subscription and stock price for periods which exceed 3 years, applies to interest from 1-year term or less deposits and 12 applies to any other interest 9 for certain mortgage and long-term municipal bonds, 1 for state and other municipal bonds, and 2 in other cases. Y. (b) in respect to a loan, debt-claim or credit guaranteed or insured by an institution for insurance or financing of international trade transactions which is wholly owned by the other Contracting State or by the Government of the other Contracting State. applies for the use of, or right to use any patent, design or model, plan, secret formula or process, for information concerning industrial or scientific experience. 1 applies for the use of, or right to use a trademark or for information concerning commercial experience, and 1 in all other cases. r. s. applies to interest income paid to a non- resident company from traded government bonds, loans provided by a foreign resident to the state in foreign currency, and deposits of foreign currency bank accounts, provided that no business or profession is conducted in Israel by the foreign resident. 26. applies in all other cases 1 applies to interest paid to financial institutions, or to publicly traded securities, 1 applies to reinsurance companies, 21 applies to non-resident suppliers of machinery and equipment or paid by financial institutions, 4 applies to entities subject to preferential tax regime, 3 applies to other interest payments a. for fully franked dividends, distributions of conduit income, etc. 3 for unfranked dividends b. applies if paid out of foreign sourced income, 2 applies if paid out of profits that are exempt or have not been taxed and 1 applies in all other cases c. applies to arm s length paymentss t. u. v. applies to railroad wagons, 3 applies to patents, trademarks and advertising, 4 applies to royalties paid to entities subject to preferential tax regime and 2 applies to other royalties applies under the participation exemption rules; 1 in other cases withholding tax is imposed on payments to non-resident individuals d. e. f. applies to film royalties and 1 applies to any other royalties 3 of profits multiplied by the applicable corporate tax rate 2 applies to patent royalties *With Effect From 1st January 217 Page

6 Contact us André Zarb Partner, Head of Tax E: Pierre Portelli Partner, Tax E: Juanita Brockdorff Partner, Tax E: T: Follow KPMG Malta: Download the KPMG Malta App: The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. 216 KPMG, a Maltese Civil Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. Printed in Malta.

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