International Taxation

Malta has published Legal Notice No. 198 of 2021, which contains the Relief of Double Taxation between Malta and Switzerland. The Legal Notice provides for the ratification of the amending protocol to the 2011 income tax treaty with Switzerland, which was signed on 16 July 2020. The protocol is the first to amend the treaty […]

The Budget Measures Implementation Act, 2021, published on the 16 of April, includes a new enabling provision (article 51A) that empowers the Minister for Finance to introduce detailed transfer pricing rules. As a result of this provision, the introduction of such rules in Malta appears imminent. This comes as no surprise and follows on the […]

US Treasury financial regulator FinCEN has begun a consultation on implementing the strict new beneficial ownership reporting rules established by the Corporate Transparency Act (CTA). The Financial Crimes Enforcement Network released the notice of proposed rulemaking to give the public its first opportunity to comment on the beneficial ownership disclosure requirements. It said in the […]

The UK will repeal the EU Interest and Royalty Directive legislation that was transposed into UK  law by virtue of Council Directive 2003/49/EC. The withdrawal of the exemption shall become effective  on the 1st  June 2021. Consequently,  companies that pay interest and royalties to other associated companies incorporated or based in the EU will have […]

The European Union announced today it has removed Barbados from its blacklist of countries it deems non-cooperative in matters of taxation, and added Dominica. The EU’s review of Barbados’ status comes just four months after the bloc’s finance ministers voted to blacklist the Caribbean island. Blacklisted jurisdictions face higher scrutiny, loss of access to EU […]

The Constitutional Court of Belgium has requested a preliminary ruling from the Court of Justice of the EU (CJEU) about exceptions to reporting tax arrangements under the EU Council’s Directive 2018/822 (DAC6). The Constitutional Court of Belgium has requested a preliminary ruling from the Court of Justice On February 19, The Belgium high court, Grondwettelijk […]

On the 1st of December 2020, Poland and Malta have signed a protocol amending the 1994 income tax treaty. According to the Polish Ministry of Finance, the protocol provides for the implementation of the minimum BEPS standards and, in particular, includes amendments providing for Withholding tax on fees for technical services; Specifically, changes to the […]

Malta’s Commissioner for Revenue has announced that the DAC6 XML Schema to be used for filing information in relation to reportable cross-border arrangements and the DAC6 XML Schema user guide are now available on the following on their website Reportable Cross-Border Arrangements On 25 May 2018 Council Directive 2011/16/EU (‘Directive on Administrative Cooperation’) was amended […]

On 17 December 2019 Legal Notice 342 introduced regulations implementing the European Union Directive on the mandatory disclosure and exchange of cross-border tax arrangements were published (commonly referred to as DAC6). The regulations had to come into force as from 1 July 2020, however their enactment was postponed due to pandemic. The new effective date […]

On 1 October 2020, Malta and Russia signed a Protocol amending the Convention for the Avoidance of Double Taxation and the prevention of Fiscal Evasion between the two countries. This new Protocol includes amendments to Article 10 of the Convention concerning dividends payments, Article 11 concerning interest payments as well as Article 24 being the Non-Discrimination […]