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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

Limitation of relief (Article 23)

Article 23 of the DTA provides that if a Malta resident person is ‘subject totax’ (see INTM332200) in Malta only in respect of theamount of any income which is remitted to or received in Malta; and not by reference tothe full amount of the income, then the relief to be allowed by the UK is limited to theamount of the income that is remitted to or received in Malta.