The Double Taxation Agreement between Switzerland and Malta entered into force on the 6th June 2012, following an announcement by the Swiss federal government that the ratification process has been completed.
The Agreement is based on the OECD Model Tax Convention and includes, inter alia, the standard provisions dealing with exchange of information. The agreement particularly provides for a withholding tax exemption for dividend and interest payments between related companies which hold at least 10% of the share capital of the company making the payment. Royalties are also exempt from withholding tax under the Agreement. It is pertinent to note, however, that Malta generally does not levy withholding tax on outbound royalties, interest and dividends.
The provisions of the Double Tax Agreement will apply as from January 1, 2013.
