2019 Armenia-Malta Income Tax Treaty Available

<p>Tax Analysts has obtained the English text of the Armenia-Malta income tax treaty signed September 24, 2019, in New York.</p> <p>Under the treaty, for dividends paid by an Armenian resident company to a beneficial owner resident in Malta, the Armenian tax may not exceed 5 percent if the beneficial owner is a company (other than a partnership) that directly holds at least 10 percent of the capital of the payer company and has invested at least €1.5 million, or the equivalent in any other currency,  in the share capital of the payer company at the date of payment of the dividends. A 10 percent rate applies in other cases. If dividends are paid by a Maltese resident company to a beneficial owner resident in Armenia, the Maltese tax on the gross amount of the dividends may not exceed the amount chargeable on the profits out of which the dividends are paid.</p> <p>Interest and royalty payments are taxable at a maximum rate of 5 percent. Both countries generally use the credit method to eliminate double taxation.</p> <p>This is the first income tax treaty between the two countries. It will enter into force upon the exchange of ratification instruments, and its provisions will generally apply from January 1 of the year following entry into force.</p>

<p><a href="/lr/resolve/-/2c6mk" title=" ">Maltese text</a>. <a href="/lr/resolve/-/2c6mp" title=" ">Related coverage</a>.</p>

<p>Tax Analysts has obtained the English text of the Armenia-Malta income tax treaty signed September 24, 2019, in New York.</p>

Tax Analysts has obtained the English text of the Armenia-Malta income tax treaty signed September 24, 2019, in New York. Under the treaty, for dividends paid by an Armenian resident company to a beneficial owner resident in Malta, the Armenian tax may not exceed 5 percent if the beneficial owner is a company (other than a partnership) that directly holds at least 10 percent of the capital of the payer company and has invested at least €1.5 million, or the equivalent in any other currency,  in the share capital of the payer company at the date of payment of the dividends. A 10 percent rate applies in other cases. If dividends are paid by a Maltese resident company to a beneficial owner resident in Armenia, the Maltese tax on the gross amount of the dividends may not exceed the amount chargeable on the profits out of which the dividends are paid. Interest and royalty payments are taxable at a maximum rate of 5 percent. Both countries generally use the credit method to eliminate double taxation. This is the first income tax treaty between the two countries. It will enter into force upon the exchange of ratification instruments, and its provisions will generally apply from January 1 of the year following entry into force.

<h4>Rate Table Instructions</h4> <ul> <li>You must enter a rate for each rate type</li> <li>Enter only one rate value per row</li> <li>You may leave the country columns blank if the rate is the same for both countries</li> <li>Country names (if entered) must exactly match the jurisdictions</li> <li>Leave the Partner Country column blank if you want the rate to apply to all partners of the Main Country</li> <li>Enter "n/a" in each rate row to hide the partner in the Main Country table</li> <li>Note that the same rates may apply for Main Country and Partner Country or the Main Country may apply different rates to the Partner Country</li> </ul> <table> <tbody> <tr><th> <div>Rate Type</div> (Dividends, Interest, Royalties)</th><th>Main Country</th><th>Partner Country</th><th>Rate</th><th>Footnote 1</th><th>Footnote 2</th><th>Footnote 3</th><th>Footnote 4</th></tr> <tr> <td>Dividends</td> <td> </td> <td> </td> <td>5/10 </td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Interest</td> <td> </td> <td> </td> <td>5 </td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Royalties</td> <td> </td> <td> </td> <td>5 </td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> </tbody> </table>

Armenia - Malta: 2019 Income Tax Agreement

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2019 Armenia-Malta Income Tax Treaty Available