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.

Israel-Malta Double Tax Treaty

Israeli Withholding Taxes

The main features of the Malta Israel tax treaty are as follows:

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.

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When navigating tax matters from Malta to Israel and from Israel to Malta, it’s essential to understand how the Double Tax Treaty between the two countries impacts taxation on income, capital gains, and other financial obligations. This treaty ensures that individuals and businesses benefit from reduced tax liabilities and avoid the risk of double taxation. By leveraging this agreement, both residents and companies can optimise their tax position when operating or investing across Malta to Israel or Israel to Malta. Please contact us should you require any more information on the Malta-Israel Double Tax Treaty and the unique tax planning opportunities.

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