On 25 February 2011, Switzerland and Malta signed a new income tax treaty and protocol, in Rome. The new treaty supersedes the Switzerland-Malta income tax treaty of 18 December 2008, which consequently will never enter into force.
The new treaty contains an exchange of information provision in line with Art. 26 of the OECD Model Convention.
The treaty provides for a withholding tax exemption for dividend payments in the case of related comp…