China & Malta Double Tax Treaty


The Double Tax Treaty Malta China entered into force on 25 August 2011. The main features of the treaty are as follows:

China Withholding Taxes

Dividend Income

The Double Tax Treaty Malta China sets out a maximum Chinese withholding tax of 5% on dividends distributed by a Chinese resident company to a Maltese resident company where the Maltese resident company holds at least 25% of the share capital of the Chinese resident company. In all other circumstances, the maximum Chinese withholding tax is 10%.

Interest Income

The Double Tax Treaty Malta China sets out a maximum Chinese withholding tax of 10% on interest paid by a Chinese resident to a Maltese resident beneficial owner of the interest income.

Royalty Income

The Double Tax Treaty Malta China sets out a maximum Chinese withholding tax of 10% on royalties paid by a Chinese resident to a Maltese resident beneficial owner of the royalty income.

Other Income

The Double Tax Treaty Malta China states certain pensions and other similar remuneration arising from Chinese sources and paid to a Maltese resident are taxable only in Malta. However such a rule does not apply to similar payments advanced by a Chinese statutory body or local authority or a political subdivision thereof for services rendered therein unless the Maltese resident individual is also a Maltese national.

Please contact us should you require any more information on the Malta China Double Tax Treaty and the unique tax planning opportunities. You can email us enquiries@papilioservices.com or call us directly on +356 2258 2000.


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