South Africa & Malta Double Tax Treaty


The Double Tax Treaty Malta South Africa was signed on the 16th of May 1997 and is currently in force. The main features of the Malta South Africa tax treaty are as follows.

South African Withholding Taxes

Dividend Income

The Double Tax Treaty Malta South Africa sets out a maximum South African withholding tax of 5% on dividends distributed by a South African resident company to a Maltese resident company.

Interest Income

The Double Tax Treaty Malta South Africa sets out a maximum South African withholding tax of 10% on interest paid by a South African resident to a Maltese resident beneficial owner of the interest income.

Royalty Income

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

Other Income

The Double Tax Treaty Malta South Africa states the definition of permanent establishment (PE) is based on the OECD model and includes the furnishing of services, including constancy services by an enterprise through employees or other personnel engaged by the enterprise for such purpose when such activity continues for more than 6 months in a 12 month period.

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