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Guernsey-Malta

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Guernsey Publishes Synthesized Text of Tax Treaty with Malta as Impacted by BEPS MLI

The Government of Guernsey has published the synthesized text of the 2000 tax treaty with Malta as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).

The synthesized text has been prepared on the basis of the MLI position of Guernsey submitted to the Depositary upon ratification on 12 February 2019 and of the MLI position of Malta submitted to the Depositary upon ratification on 18 December 2017. The authentic legal texts of the Agreement and the MLI take precedence and remain the legal texts applicable. The MLI applies for the Guernsey-Malta treaty as follows:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
  • with respect to all other taxes in Guernsey, for taxes levied with respect to taxable periods beginning on or after 1 December 2019; and
  • with respect to all other taxes in Malta, for taxes levied with respect to taxable periods beginning on or after 1 January 2020.

MLI synthesized texts of Guernsey's tax treaties can be found on the Double taxation arrangements webpage of the Government website.

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