Treaty Planning and other double tax relief advice

Malta has an extensive double tax treaty network which enables Maltese resident companies and individuals to claim treaty benefits if they are subject to tax in Malta. Such benefits include:

(a) defining a permanent establishment and determine what profits can be attributable to a permanent establishment and thus subject to tax where that PE is situated;

(b) defining tie-breaker rules to be able to determine the country of residence of a company or an individual;

(c) allocating exclusive taxing rights to Malta as a residence country in certain situations of passive income arising in another country (thereby avoiding foreign taxes);

(d) allocation limited taxing rights to the source country by establishing lower withholding taxes for dividends, interest and royalties arising in another country and derived by a Malta resident.

Altima Malta Limited has been involved in tax planning exercises involving treaty planning and ensuring that tax benefits are maximised without falling foul of treaty shopping and other anti-abuse provisions. For further information on this topic, please contact us on