Israel & Malta Double Tax Treaty


The Double Taxation Relief Treaty between Malta and Israel was signed in Jerusalem on 28 July 2011 and is currently in force since 8 December 2013. The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is also in force. The main features of the Double Tax Treaty Malta Israel are as follows:

Israeli Withholding Taxes

Dividend Income

The Double Tax Treaty Malta Israel states that there is no Israeli withholding tax on dividends distributed by an Israeli resident company to a Maltese resident beneficial owner of the dividend income where the Maltese resident company holds directly at least 10% of the capital of the company paying the dividend.

In all other cases (including for distributions made by an Israeli real estate investment company where the Maltese resident beneficial owner holds directly less than 10% of the capital of the real estate investment company paying the dividend), the maximum Israeli withholding tax is 15%.

Interest Income

The Double Tax Treaty Malta Israel states that the maximum Israeli withholding tax on interest paid by an Israeli resident to a Maltese resident beneficial owner of the interest income is 5%.

Royalty Income

The Double Tax Treaty Malta Israel states that no Israeli withholding tax is charged on royalties paid by an Israeli resident to a Maltese resident beneficial owner of the royalty income.

Other Income

The Double Tax Treaty Malta Israel states that pensions and other similar remuneration from Israeli sources to a Maltese resident individual may only be taxed in Malta.

However, this does not apply for pensions paid by, or out of funds created by, Israel or a political subdivision or a local authority for services rendered to Israel, which are taxable in Israel only.

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


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