Russia and Malta signed Double Taxation Agreement

Russia and Malta signed Double Taxation Agreement

The government of Russian Federation and the government of Malta have signed the Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

The Agreement and the related Protocol were signed on April 24, 2013 at the Ministry of Finance   by the Ambassador of Malta to the RF, Raymond Sarsero and the Deputy Minister of Finance, Sergey Shatalov. 

The Minister of Foreign Affairs, Dr. George W. Vella, highlighted  that the signing  of this Agreement showed the commitment of the Ministry for Foreign Affairs to promote economic diplomacy and to invite foreign direct investments to Malta and to broaden further trade and investment  between two countries on the basis of mutually equal benefit.

According to the articles of the Agreement the following taxes to be charged:

(1) Taxes on dividends. Where the dividends are paid by the company which is a resident of Russia to a resident of Malta who is the beneficial owner thereof, the tax so charged in Russia shall not exceed:

  • 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the capital of the company paying the dividends and this holding amount to at least 100,000 Euro;
  • 10 per cent of the gross amount of the dividends in all other cases (Article 10 item 2).

(2) Taxes on interest. If the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the gross amount of the interest (Article 11 item 2).

(3) Taxes on royalty. If the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the gross amount of the royalties (Article 12 item 2).

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