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HMRC internal manual

International Manual

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

UK interest paid to a resident of Malta (Article 11)

UK interest paid to a resident of Malta who is the beneficial owner of the interest andis ‘subject to tax’ (see INTM332210) in Malta in respect ofthe interest is taxable in the UK at 10%.

Exceptionally, UK interest may be exempted from UK income tax under the provisions ofArticle 11 paragraph (9) of the Convention. The payments covered by these provisions are

  • interest paid on a loan made, guaranteed or insured or any other debt-claim or credit guaranteed or insured, by an institution beneficially owned by the Government of Malta or any agency or instrumentality of the Government of Malta.

If you have any doubts about whether the claimant may be entitled to full relief fromUK tax, send the file to Technical Advice Group before taking further action.