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HMRC internal manual

International Manual

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

Other UK income paid to a resident of Malta (Article 21)

Providing that the claimant is ‘subject to tax’ (see INTM332210)on the income in Malta, full relief is available to the beneficial owner of any incomethat is not expressly mentioned in any of the Articles of the UK/Malta Double TaxationConvention. See INTM344510.

No relief can be allowed under the terms of this article for income thatis paid out of trusts or income that is paid during the administration period of a UKestate.