Russia & Malta Double Tax Treaty

The Double Tax Treaty Malta Russia sets out a maximum Russian withholding tax of 5% on dividends paid by a company resident in Russia to a company (other than a partnership) resident in Malta which holds directly at least 25% of the capital of the company paying the dividend, and this holding amounts to at least €100k. In all other cases, the maximum Russian withholding tax is 10%.

The Double Tax Treaty Malta Russia sets out a maximum Russian withholding tax of 5% on interest paid by a resident of Russia to a resident of Malta.

The Double Tax Treaty Malta Russia sets out a maximum Russian withholding tax of 5% on royalties paid by a resident of Russia to a resident of Malta.

The Double Tax Treaty Malta Russia definition of a permanent establishment (PE) is based on the OECD Model, and includes the possibility of a services PE.

The Double Tax Treaty Malta Russia includes a limitation of benefit clause whereby the benefits of the treaty do not apply “if the main purpose or one of the main purposes of such resident or a person connected to such resident was to obtain the benefits of the Convention”. However, the LOB clause does not apply where a company is engaged in substantive business operations in the contracting state of which it is a resident.