SolvedDT12905 | Double Taxation Relief Manual: Malta: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Malta are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full datails. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 0% | 10 |
| Dividends on direct investments | 0% | 10 |
| Property income dividends | 0% (Note 1) | 10 |
| Interest | 10% (Note 2) | 11 |
| Royalties | 10% (Note 2) | 12 |
| Government pensions | Taxable only in Malta unless the individual is a resident and national of the UK | 19 |
| Other pensions | Taxable only in the UK | 18 |
| Arbitration | Yes | Under MLI |
Note 1: No relief from UK income tax is due in respect of a UK property income dividend beneficially owned by a resident of Malta.
Note 2: To qualify for the convention rate, the beneficial owner must be subject to tax in the UK.