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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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DT Agreements: Malta - Income from a UK source paid to a resident of Malta

UK dividends paid to a resident of Malta (Article 10) - direct investor

There is no provision for payment of tax credit attached to UK dividends to a directinvestor company in Malta.

See INTM343540 for an explanation of the term “directinvestor”.