Double taxation relief clarifies no additional Maltese dividend withholding and narrows treaty scope for shipping and freeport regimes. The Protocol confirms that under Malta's Full Imputation System no additional withholding tax on dividends is imposed beyond tax on the company's profits, excludes from Articles 6-22 persons or companies benefitting from Malta's Merchant Shipping and Freeport fiscal regimes (or similar future regimes) to the extent they are not subject to tax, and provides that Malta's current assistance in collection of taxes is limited to EU members but may be extended by law change with mutual agreement between competent authorities on procedures.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Double taxation relief clarifies no additional Maltese dividend withholding and narrows treaty scope for shipping and freeport regimes.
The Protocol confirms that under Malta's Full Imputation System no additional withholding tax on dividends is imposed beyond tax on the company's profits, excludes from Articles 6-22 persons or companies benefitting from Malta's Merchant Shipping and Freeport fiscal regimes (or similar future regimes) to the extent they are not subject to tax, and provides that Malta's current assistance in collection of taxes is limited to EU members but may be extended by law change with mutual agreement between competent authorities on procedures.
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