10 November 2006

Malta publishes tax treaty with San Marino

On 10th November 2006 Malta published the ‘Convention between Malta and the Republic of San Marino with respect to taxes on income’.  The treaty was published in the Government Gazette number 17994.

The tax treaty provides that dividends paid by a company which is a resident of San Marino to a Maltese shareholder shall not exceed 10% of the gross amount of dividends.  If the Maltese shareholder is a company which owns at least 25% of the capital of the company in San Marino, then the withholding tax is reduced to 5%.  Both interest and royalties are exempt from tax in the country of source.

Both interest and royalties are exempt from tax in the country of source.

The treaty is based on the OECD model convention and includes an article on ‘Mutual Agreement Procedure’.  The treaty became operative from basis year 2006.

To view the full version of the treaty click here.