Following the ratification of Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (‘MLI’) back in end of 2018, the MLI came into force in Malta on the 1 April, 2019.

The MLI is an OECD project with the main objective being that of providing tangible solutions for governments to eliminate the gaps in existing international tax rules by transposing results from the OECD/G20 BEPS Project into bilateral tax treaties worldwide. The MLI aims to lessen the opportunity for tax avoidance by multinational companies.

The MLI has resulted into modifications of some of the double tax treaties that Malta has entered into over the years. In this regard, the Commissioner for Revenue has already indicated which of the Double tax Treaties have so far been modified as a result of the MLI. Kindly refer to the below link indicating which treaties have been modified:

https://cfr.gov.mt/en/inlandrevenue/itu/Pages/Double-Taxation-Conventions.aspx

Author: Stephanie Aquilina Galea, Tax Supervisor, Tax Compliance Department