The amending protocol to the 2011 income tax treaty between Malta and Switzerland entered into force on 3 November 2021. The protocol is the first to amend the treaty and includes the following changes:
- The preamble is replaced in line with BEPS standards;
- Article 7 (Business Profits) is amended with the addition of a new paragraph 7 providing that a Contracting State shall make no adjustment to the profits that are attributable to a permanent establishment of an enterprise of one of the Con…