France & Malta Double Tax Treaty
The Double Tax Treaty Malta France, as amended, was originally signed on 25 July 1977 and is currently in force. The main features of the treaty are as follows:
French Withholding Taxes
The Double Tax Treaty Malta France states there is no French withholding tax on dividends distributed by a French resident company to a Maltese resident company where the Maltese resident company holds at least 10% of the share capital of the French resident company. In all other circumstances, the maximum French withholding tax is 15%.
The Double Tax Treaty Malta France sets our a maximum French withholding tax of 5% on interest paid by a French resident to a Maltese resident beneficial owner of the interest income.
The Double Tax Treaty Malta France sets out a maximum French withholding tax of 10% on royalties paid by a French resident to a Maltese resident beneficial owner of the royalty income.
The Double Tax Treaty Malta France states that payments made after retirement in consideration of past employment or by way of compensation for injuries received in connection with past employment from French sources to a Maltese resident individual in consideration of past employment shall be taxable only in Malta. However, such a rule does not apply to similar payments advanced by a French statutory body or local authority or a political subdivision thereof services rendered therein unless the Maltese resident individual is also a Maltese national.
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