Double Tax Treaty Malta Russia

Double Tax Treaty Malta Russia

The Double Tax Treaty Malta Russia came into force on the 22 May 2014. The main features of the treaty are as follows:

Dividend Income

The Double Tax Treaty Malta Russia sets out a maximum Russian withholding tax of 5% on dividends paid by a company resident in Russia to a company (other than a partnership) resident in Malta which holds directly at least 25% of the capital of the company paying the dividend, and this holding amounts to at least €100k. In all other cases, the maximum Russian withholding tax is 10%.

Interest Income

The Double Tax Treaty Malta Russia sets out a maximum Russian withholding tax of 5% on interest paid by a resident of Russia to a resident of Malta.

Royalty Income

The Double Tax Treaty Malta Russia sets out a maximum Russian withholding tax of 5% on royalties paid by a resident of Russia to a resident of Malta.

Other Income

The Double Tax Treaty Malta Russia definition of a permanent establishment (PE) is based on the OECD Model, and includes the possibility of a services PE.

The Double Tax Treaty Malta Russia includes a limitation of benefit clause whereby the benefits of the treaty do not apply “if the main purpose or one of the main purposes of such resident or a person connected to such resident was to obtain the benefits of the Convention”. However, the LOB clause does not apply where a company is engaged in substantive business operations in the contracting state of which it is a resident.

Please contact us for more information on any tax planning opportunities the Double Tax Treaty Malta Russia may offer for the purpose of making your organisation more tax efficient.

Click below to go back to all of the double taxation treaties Malta has in force: