Curacao & Malta Double Tax Treaty

The Government of Malta has published the text of the new Double Taxation Treaty between Malta and the Kingdom of the Netherlands in respect of Curacao. The main features of the treaty are as follows:

Dividend Income

The Double Tax Treaty Malta Curacao sets out a maximum Curacao withholding tax of 0% on dividends distributed by a Curacao resident company to a Malta resident shareholder, if the Malta shareholder is a company which holds directly at least 10% of the capital of the company paying the dividends. In all other cases, the Curacao withholding tax shall not exceed 5%.

No Maltese withholding tax is charged on dividends distributed by a Malta resident company to a Curacao resident shareholder.

Interest Income

The Double Tax Treaty Malta Curacao states that interest arising in Curacao and paid to a Malta resident person shall only be taxable in Malta. Interest arising in Malta and paid to a Curacao resident person shall only be taxable in Curacao. This does not prevent the application of the provisions in the EU Savings Directive.

No Maltese withholding tax is charged on interest paid by a Malta resident person to a Curacao resident person.

Royalty Income

The Double Tax Treaty Malta Curacao states that royalties arising in Curacao and paid to a Malta resident person shall only be taxable in Malta. Royalties arising in Malta and paid to a Curacao resident person shall only be taxable in Curacao.

No Maltese withholding tax is charged on royalties paid by a Malta resident person to a Curacao resident person.

Pension Income

The Double Tax Treaty Malta Curacao states that pensions and other similar remuneration paid to a resident of Malta in consideration of past employment shall be taxable only in Malta. Where such remuneration is not periodic in nature and is paid in consideration of past employment in Curacao, the rewards may be taxed in Curacao.

Pensions and other payments made under the provisions of a public social security system and other public pensions shall be taxable only in the country paying the pension.

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