Malta Double Taxation Agreements

This article presents information about the double taxation treaties (DTTs) signed by Malta with countries worldwide. Our Maltese lawyers can assist company owners with a wide range of tax-related matters linked to business.

Do you offer support in double taxation to foreign clients?

Yes, our law firm in Malta has English-speaking specialists in its team and they can assist foreign clients.

What is a double taxation agreement and what purpose does it have?

A specific arrangement through which various types of income are protected against double taxation.

How are double tax agreements known in Malta?

• Double Taxation Treaties or DTTs,
• Double Taxation Arrangements or DTAs,
• Double Taxation Conventions.

Who can benefit from the provisions of the DTTs signed by Malta?

• international companies,
• natural persons.

How many DTAs did Malta sign?

About 80, but only 78 are at present in force.

What types of income are covered by a double tax treaty signed by Malta?

• Dividends,
• Royalties,
• Salaries,
• Pensions,
• Real estate income,
• Business income, etc.

Is there a specific tax convention/model followed by Malta for its DTTS?

Yes, the OECD Model Tax Convention.

What are the key provisions of double taxation agreements signed by Malta?

• taxes paid by companies or natural persons in Malta are covered by the DTTs signed/in force. This means that no tax abroad shall be paid,
• according to Maltese law, there is 0% withholding tax on dividends, interest, and royalties to non-residents with permanent establishments in Malta,
• a tax credit can be claimed through a DTA signed by Malta if the taxes have been paid where the income was generated.

What are the methods/options to avoid the double taxation in Malta?

• mostly, the tax credit mechanism through bilateral DTTs.
• there is also the reciprocal tax credit mechanism in case there is no DTT signed with Malta.

How is the tax residence determined when applying for a DTT provision?

• the Maltese tax authorities can establish or determine the primary tax right, based on the local laws and company establishment,
• dual residents (in Malta and in another country) might cause tax payment conflicts. But the Maltese double tax agreements have specific provisions for these situations.

What is the Mutual Agreement Procedure – MAP?

The Mutual Agreement Procedure is a method through which tax conflicts involving double tax treaties can be solved. Such conflicts normally arise due to the dual residence of companies or individuals.

Are there any updates on double tax arrangements signed by Malta?

• the Maltese authorities concentrate on optimizing the dispute resolution protocols to avoid tax conflicts,
• the Malta – San Marino DTT entered into force in April 2026,
• the Malta – Romania DTT entered into force in May 2026,
• Individual Tax Programme rules have been recently revised.

If you want to know more details about the double taxation treaties signed by Malta, you can contact our Maltese law firm. Our lawyers can also help you start an LLC (Private Limited Company) in Malta.