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of <h1>Article 10 of India-Malta DTAA: Tax on Dividends Capped at 10% for Maltese Residents; Special Rules Apply for Permanent Establishments.</h1> Article 10 of the Double Taxation Avoidance Agreement (DTAA) between India and Malta addresses the taxation of dividends. Dividends paid by a company in one Contracting State to a resident of the other may be taxed in both States. However, the tax rate imposed by India on dividends paid to a Maltese resident should not exceed 10% of the gross amount, while Malta's tax on dividends paid to an Indian resident should not exceed the tax on the profits from which the dividends are paid. The term 'dividends' includes income from shares and similar rights. Provisions do not apply if the dividends are effectively connected to a permanent establishment or fixed base in the other State. Additionally, a State cannot tax dividends paid by a company from the other State unless the dividends are to a resident or connected to a permanent establishment.
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