Switzerland - Malta Double Taxation Agreement

Dr. Trudy Marie Attard | 29 Nov 2011

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Switzerland and Malta have signed a new Double Tax Agreement in a bid to further the development of bilateral economic relations and foster transparency between the two states.  This new Agreement is a development of a previous Agreement signed in 2008, which never came became effective. The new Agreement is thus currently awaiting ratification. In the meantime, the only the Double Tax Treaty in force between the two states relates to Ships and Aircraft.
In the beginning of February 2011, Switzerland announced the conclusion of negotiations with the Maltese authorities of the revision of the 2008 Agreement. Signed on the 25th February 2011, Switzerland and Malta agreed to a withholding tax exemption for dividend payments in the case of related companies with a capital holding of at least 10% in the company making the payment. This exemption applies as long as the participating interest is held for at least one year. The new Agreement includes provisions for the exchange of tax information in accordance with the OECD Model Tax Convention.  In addition, the most-favoured-nation treatment of Switzerland was agreed to in relation to an arbitration clause so that should Malta negotiate an arbitration clause with another country, this would automatically become applicable to the Switzerland-Malta treaty.
Switzerland has ratified the Treaty and is now awaiting Malta’s ratification. This new agreement benefits the economies of both countries and allows for closer relations between the two states. It is intended to boost interest in Malta’s opportunities in this field, particularly as regards the links to the Southern Mediterranean region and the Near East.
The Swiss-Maltese Chamber of Commerce, which has offices in Switzerland, Malta Enterprise and MFSA, in addition to individual initiatives, continually strive for new investment possibilities.  Around 460 active companies with Swiss shareholding are registered in Malta as well as a number of collective investment schemes which have Swiss managers, coordinators and administrators.

[Full List of Malta Double Taxation Agreements]

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