Germany & Malta Double Tax Treaty


The Double Tax Treaty Malta Germany was signed on the 8 March 2001 and is currently in force. The main features of the tax treaty are as follows.

German Withholding Taxes

Dividend Income

The Double Tax Treaty Malta Germany sets out a maximum German withholding tax of 5% on dividends distributed by a German resident company to a Maltese resident company where the Maltese resident company holds at least 10% of the share capital of the German resident company. In all other circumstances, the maximum German withholding tax is 15%.

Interest Income

The Double Tax Treaty Malta Germany outlines that there is no German withholding tax on interest paid by a German resident to a Maltese resident beneficial owner of the interest income.

Royalty Income

The Double Tax Treaty Malta Germany states that there is no German withholding tax on royalties paid by a German resident to a Maltese resident beneficial owner of royalty income.

Other Income

The Double Tax Treaty Malta Germany outlines that income generated by artists and sportsmen with respect to activities exercised in Malta including the right to use personal rights, the toleration of the recording and transmission of artistic and athletic performances by radio and television may be taxed in Malta. It is to be noted that when a non resident of Malta derives income from entertainment activities exercised in Malta for a period no exceeding fifteen days in the year preceding a year of assessment, the tax charged is 10% on the gross payment received in respect of those entertainment activities.

Please contact us should you require any more information on the Malta Germany 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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