Malta – Georgia Treaty details |
| Written by Franco Falzon — Mon, 15 March 2010 |
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The Malta – Georgia Treaty has entered into force in 2010. The treaty is applicable from the 1st of January 2011. In general, the double tax agreement follows the OECD Model Convention. What could be deemed as a major departure from the Model Convention is the removal of a withholding tax on dividends, interest and royalties. In fact, Georgia is restricted from levying any withholding tax on dividends, interest and royalty distributions to residents of Malta. These provisions are also in line with its domestic tax policies promising the abolishment of domestic withholding tax on dividends and interest distributions to non-residents as from 2012. One may notice the existence of a provision on independent personal services in the treaty (which was removed in the 2005 and 2008 OECD Model Conventions.) The provisions in the treaty contemplate that income derived by an individual in respect of professional services is exempt from tax in the source country and taxable only in the Residence State of the individual. Individuals having a fixed based regularly available to them are precluded from the tax exemption in the country of source. Professional services are defined to include independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. The treaty eliminates double taxation by the use of the credit method. Georgia currently has a treaty in force with Armenia, Austria, Azerbaijan, Belgium, Bulgaria, China, Czech Republic, Estonia, Finland, Germany, Greece, Italy Kazakhstan, Latvia, Lithuania, The Netherlands, Poland, Romania, Turkmenistan, Ukraine United Kingdom and Uzbekistan. For more information, kindly contact:Neville Cutajar - Managing Partner: neville.cutajar@3a.com.mt
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| Last Updated on Thu, 30 December 2010 |
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