Details of the income tax treaty and protocol between Isle of Man and Malta, signed on 23 October 2009, have become available. The treaty was concluded in the English language. The treaty follows the OECD Model Convention with certain deviations described below.
Regarding dividends, the treaty provides for the right to tax for the recipient's state of residence. However, as long as Malta operates a full imputation system in respect to the taxation of the compan…