Switzerland & Malta Double Tax Treaty


The Double Taxation Relief Treaty between Malta and Switzerland was signed in Rome on 25 February 2011 and is currently in force since 6 July 2012. The main features of the Double Tax Treaty Malta Switzerland are as follows:

Swiss Withholding Taxes

Dividend Income

The Double Tax Treaty Malta Switzerland states that there is no Swiss withholding tax on dividends distributed by a Swiss resident company to a Maltese resident company where the Maltese resident company holds at least 10% of the share capital of the Swiss resident company for at least a year, if both companies are subject to tax and have been set up in the form of a limited company. In all other cases, the maximum Swiss withholding tax is 15%.

Interest Income

The Double Tax Treaty Malta Switzerland sets out a maximum Swiss withholding tax of 10% on interest paid by a Swiss resident to a Maltese resident beneficial owner of the interest income. No withholding tax is charged on interest payments in connection with the sale on credit of any industrial, commercial or scientific equipment, in connection with the sale on credit of any merchandise by one enterprise to another enterprise and on any loan of whatever kind granted by a bank. Furthermore, no withholding tax is charged on interest payments between associated companies.

Royalty Income

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

Other Income

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

However, this does not apply for pensions paid by the Swiss state or a political subdivision or a local authority thereof, which are taxable in Switzerland only.

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