S.L. 123.105 Art. 2Arrangements to have effect. The Convention for with respect to This Contracting 1. This State, 2. There income, or on movable or 3. The (a) in (i) (ii) (iii) (b) in the 4. The taxes which are or in place of, the shall notify each respective 1. For the (a) the waters, wherein in accordance its legis

It is hereby declared:

(a) that the arrangements specified in the Convention set out in the Schedule to this Order have been made with Ireland with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of Ireland: - the income tax; - the corporation tax; and - the capital gains tax;

(b) that it is expedient that those arrangements should have effect;

(c) that the Convention has entered into force on the 15 January, 2009.

*https://cfr.gov.mt/en/inlandrevenue/itu/Documents/Malta%20-%20Ire-land%20DTA%20(synthesised%20text).pdf FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Government of Malta and the Government of Ireland, desiring to conclude a the avoidance of double taxation and the prevention of fiscal evasion taxes on income, have agreed as follows:

Article 1 PERSONS COVERED Convention shall apply to persons who are residents of one or both of the States. Article 2

TAXES COVERED Convention shall apply to taxes on income imposed by a Contracting irrespective of the manner in which they are levied. shall be regarded as taxes on income all taxes imposed on total elements of income, including taxes on gains from the alienation of immovable property.

existing taxes to which this Convention shall apply are: the case of Ireland: the income tax; the corporation tax; the capital gains tax; (hereinafter referred to as "Irish tax"); the case of Malta: income tax; (hereinafter referred to as "Malta tax"). Convention shall apply also to any identical or substantially similar imposed after the date of signature of the Convention in addition to, existing taxes. The competent authorities of the Contracting States other of any significant changes which have been made in their taxation laws. Article 3

GENERAL DEFINITIONS purposes of this Convention, unless the context otherwise requires: term "Ireland" includes any area outside the territorial waters of Ireland which, in accordance with international law, has been or may hereafter be designated under the laws of Ireland concerning the Continental Shelf, as an area within which the rights of Ireland with respect to the sea-bed and sub-soil and their natural resources may be exercised; superjacent water column adjacent to the territorial Malta exercises sovereign rights, jurisdiction, or control with international law and its national law, including relating to the exploration of the continental shelf and natural resources;

(c) the terms "a Contracting State" and "the other Contracting Ireland or Malta, as the context requires;

(d) the term "person" includes an individual, a company and of persons;

(e) the term "company" means any body corporate or any treated as a body corporate for tax purposes;

(f) the terms "enterprise of a Contracting State" and "enterprise Contracting State" mean respectively an enterprise resident of a Contracting State and an enterprise carried of the other Contracting State;

(g) the term "international traffic" means any transport by operated by an enterprise of a Contracting State, except or aircraft is operated solely between places in the other State;

(h) the term "competent authority" means:

(i) in Ireland: the Revenue Commissioners or representative;

(ii) in Malta: the Minister responsible for finance representative;

(i) the term " national" means:

(i) in relation to Ireland, any citizen of Ireland and partnership or association deriving its status as laws in force in Ireland;

(ii) in relation to Malta, any individual possessing Malta and any legal person, partnership or association status as such from the laws in force in Malta.