Vietnam & Malta Double Tax Treaty

The Government of Malta has just published the text of the new Double Taxation Treaty between Malta and Vietnam. The main features of the treaty are as follows:

Vietnam Withholding Taxes

Dividend Income

The Double Tax Treaty Malta Vietnam sets out a maximum Vietnamese withholding tax of 5% on dividends distributed by a Vietnam resident company to a Malta resident shareholder, if the Malta shareholder is a company which holds directly at least 50% of the voting power of the company paying the dividends. In all other cases, the Vietnamese withholding tax shall not exceed 15%.

No Maltese withholding tax is charged on dividends distributed by a Malta resident company to a Vietnam resident shareholder.

Interest Income

The Double Tax Treaty Malta Vietnam sets out a maximum Vietnamese withholding tax of 10% on interest arising in Vietnam and paid to a Malta resident beneficial owner of the interest.

No Maltese withholding tax is charged on interest paid by a Malta resident person to a Vietnam resident person.

Royalty Income

The Double Tax Treaty Malta Vietnam sets out a maximum Vietnamese withholding tax of 5% on royalties paid as consideration for any patent, design or model, plan, secret formula or process or for information concerning industrial or scientific experience. A withholding tax of 10% is charged on royalties paid as consideration for a trademark or for information concerning commercial experience and a withholding tax of 15% is charged on royalties in all other cases.

No Maltese withholding tax is charged on royalties paid by a Malta resident person to a Curacao resident person.

Pension Income

The Double Tax Treaty Malta Vietnam states that pensions and other similar remuneration paid to a resident of Malta in consideration of past employment shall be taxable only in Malta. However, this does not apply to pensions paid by, or out of funds created by Vietnam or a local authority thereof.

Pensions and other payments made under a public welfare scheme which is part of the social security system shall be taxable only in the country paying the pension.

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