DT12905 - Malta: Treaty summary

The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Malta are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full datails. The text of the treaty can be found on gov.uk.

Subject	Comments	Article
Portfolio dividends	0%	10
Dividends on direct investments	0%	10
Property income dividends	0% (Note 1)	10
Interest	10% (Note 2)	11
Royalties	10% (Note 2)	12
Government pensions	Taxable only in Malta unless the individual is a resident and national of the UK	19
Other pensions	Taxable only in the UK	18
Arbitration	Yes	Under MLI

Note 1: No relief from UK income tax is due in respect of a UK property income dividend beneficially owned by a resident of Malta.

Note 2: To qualify for the convention rate, the beneficial owner must be subject to tax in the UK.