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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Malta: Source of income

Article 22(3) of theagreement provides that profits, income and capital gains owned by a United Kingdom resident which may be taxed in Malta under the provisions of the agreement are deemed to arise from sources in Malta.

Interest and royalties are deemed to arise in the country of which the payer is a resident (Articles 11(5) and 12(5) of the agreement).