Luxembourg & Malta Double Tax Treaty

The Double Tax Treaty Malta Luxembourg, as amended, was originally signed on 29 April 1994. Luxembourg Withholding Taxes of May 2010. The main features of the treaty are as follows:

Luxembourg Withholding Taxes

Dividend Income

The Double Tax Treaty Malta Luxembourg sets out a maximum Luxembourg withholding tax of 5% on dividends distributed by a Luxembourg resident company to a Maltese resident company where the Maltese resident company holds at least 25% of the share capital of the Luxembourg resident company. In all other circumstances, the maximum Luxembourg withholding tax is 15%.

Interest Income

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

Royalty Income

The Double Tax Treaty Malta Luxembourg sets out a maximum Luxembourg withholding tax of 10% on royalties paid by a Luxembourg resident to a Maltese resident beneficial owner of the royalty income.

Other Income

The Double Tax Treaty Malta Luxembourg states that all profits from any international transport by a ship or aircraft operated by an enterprise in Malta, except when the ship or aircraft is operated solely between Luxembourg and a third state shall be taxable in Malta.

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