Full imputation system limits dividend withholding; protocol exempts specially treated shipping and licensed entities and governs tax collection assistance. The Protocol confirms that under Malta's full imputation system no withholding tax is charged on dividends in addition to company tax; it excludes Articles 6-22 in respect of persons or companies enjoying special fiscal treatment under specified Malta laws that exempt profits from tax; and it provides that changes permitting tax collection assistance with non-EU countries must be notified and the competent authorities will mutually agree the mode of assistance.
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.
Full imputation system limits dividend withholding; protocol exempts specially treated shipping and licensed entities and governs tax collection assistance.
The Protocol confirms that under Malta's full imputation system no withholding tax is charged on dividends in addition to company tax; it excludes Articles 6-22 in respect of persons or companies enjoying special fiscal treatment under specified Malta laws that exempt profits from tax; and it provides that changes permitting tax collection assistance with non-EU countries must be notified and the competent authorities will mutually agree the mode of assistance.
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