The Double Tax Treaty which was signed between Switzerland and Malta in 2011 has entered into force in July 2012. The Treaty provisions will be effective as from 1 January 2013. The Treaty, which replaces the Treaty signed on 18 December 2008, is generally based on the OECD Model (including the exchange of information article). The treaty provides for a withholding tax exemption for dividend and interest payments between related companies with a capital stake of at least 10% in the company making the payment.
The treaty also provides for an exemption from withholding tax on royalties.