Uruguay & Malta Double Tax Treaty


The Double Taxation Relief Treaty between Malta and Uruguay was signed in Rome on 11 March 2011 and is currently in force since 13 December 2012. The main features of the Double Tax Treaty Malta Uruguay are as follows:

Uruguayan Withholding Taxes

Dividend Income

The Double Tax Treaty Malta Uruguay states that the maximum Uruguayan withholding tax on dividends distributed by a Uruguayan resident company to a Maltese resident company where the Maltese resident company holds at least 25% of the share capital of the Uruguayan resident company is 5%.

In all other cases, the maximum Uruguayan withholding tax is 15%.

Interest Income

The Double Tax Treaty Malta Uruguay states that the maximum Uruguayan withholding tax on interest paid by a Uruguayan resident to a Maltese resident beneficial owner of the interest income is 10%.

Royalty Income

The Double Tax Treaty Malta Uruguay states that the maximum Uruguayan withholding tax on royalties paid by a Uruguayan resident to a Maltese resident beneficial owner of the royalty income is 5% on royalties for the use of, or the right to use, any industrial, commercial or scientific equipment and copyright of literary, artistic or scientific work.

In all other cases, the maximum Uruguayan withholding tax is 10%.

Other Income

The Double Tax Treaty Malta Uruguay states that pensions and other similar remuneration from Uruguayan 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, Uruguay or a political subdivision or local authority thereof, which are taxable in Uruguay only.

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