← Malta

L.S. 123.138 Ordni dwar Ħelsien minn Taxxa Doppja (Taxxi fuq l-Income) (Ir-Renju tal-Għarabja Sawdita)

Obsah (4)Article 4Article 7Article 10Article 25

DOUBLE TAXATION RELIEF (TAXES ON INCOME) (THE KINGDOM OF SAUDI ARABIA) [ S.L.123.138 SUBSIDIARY LEGISLATION 123.138 DOUBLE TAXATION RELIEF (TAXES ON INCOME) (THE KINGDOM OF SAUDI ARABIA) ORDER 15th Ja

Article 4

(Residence) it is understood that the term "resident of a Contracting State" includes: (

  1. a)a pension scheme established in that State; and (
  2. b)an organisation that is established and is operated exclusively for DOUBLE TAXATION RELIEF (TAXES ON INCOME) (THE KINGDOM OF SAUDI ARABIA) [ S.L.123.138 17 religious, charitable, scientific, cultural or educational purposes (or for more than one of those purposes) and that is a resident of that State according to its laws, notwithstanding that all or part of its income or gains may be not subject or exempt from tax in that State. 2.

Article 7

(Business Profits) it is understood that: (

  1. a)business profits derived by an enterprise of a Contracting State from the exportation of merchandise to the other Contracting State shall not be taxed in that other Contracting State. Where export contracts include other activities carried on in the other Contracting State profits derived from such activities may be taxed in the other Contracting State; (
  2. b)the term “business profits” includes, but is not limited to income derived from manufacturing, mercantile, banking, insurance, from the operation of inland transportation, the furnishing of services and the rental of tangible personal movable property. Such a term does not include the performance of personal services by an individual either as an employee or in an independent capacity. 3.

Article 10

(Dividends) it is understood that: (

  1. a)The provisions of paragraph 2(
  2. b)of Article 10 shall continue to apply in Malta as long as Malta operates the full imputation system of taxation of company profits and of the subsequent distribution of such profits to the company’s shareholders. If the present system is changed, the Contracting States shall consult with each other to consider whether any such change in Malta’s system of taxation would necessitate any revision of the provisions of Article 10. (
  3. b)Notwithstanding any provision of the Convention, profits of a company of a Contracting State carrying on business in the other Contracting State through a permanent establishment situated therein may, after having been taxed under Article 7, be taxed on the remaining amount in the Contracting State in which the permanent establishment is situated and the tax so charged shall not exceed 5 per cent. 4.

Article 25

(Exchange of Information) it is understood that information received under the said Article shall be used only for the purposes of the taxes covered by the Convention. IN WITNESS WHEREOF the undersigned, being duly authorised thereto by their respective Governments, have signed this Protocol. DONE in duplicate at Riyadh 4th day of January 2012 corresponding to the 10th day of Safar 1433, in the English and Arabic languages, both texts being equally authentic. ON BEHALF OF THE GOVERNMENT OF MALTA ON BEHALF OF THE GOVERNMENT OF THE KINGDOM OF SAUDI ARABIA Tonio Borg Deputy Prime Minister and Minister of Foreign Affairs Ibrahim A. Al-Assaf Minister of Finance

🔗 Għas-sors uffiċjali

AI explanation based on the official legal text. Indicative, not a substitute for legal advice.