S.L. 123.109 Art. 2Arrangements to have effect. The Agreement for with respect Have agreed This Contracting 1. This behalf of a authorities, 2. There on total taxes on gains total amounts appreciation. 3. The (a) in (b) in 4. This taxes which are or in place of, shall notify respective 1. For the legislation, it, inte

It is hereby declared:-

(a) that the arrangements specified in the Agreement set out in the Schedule to this Order have been made with the Government of Georgia with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of Georgia:

(i) profit tax,

(ii) income tax,

(iii) property tax;

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

(c) that the Convention has entered into force on the 30th December, 2009. SCHEDULE

AGREEMENT BETWEEN THE GOVERNMENT OF MALTA AND THE GOVERNMENT OF GEORGIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

Government of Georgia and the Government of Malta desiring to conclude an the avoidance of double taxation and the prevention of fiscal evasion to taxes on income and on capital, as follows: Article 1 PERSONS COVERED

Agreement shall apply to persons who are residents of one or both of the States.

Article 2 TAXES COVERED Agreement shall apply to taxes on income and on capital imposed on Contracting State or of its political-administrative subdivisions or local irrespective of the manner in which they are levied. shall be regarded as taxes on income and on capital all taxes imposed income, on total capital, or on elements of income or of capital, including from the alienation of movable or immovable property, taxes on the of wages or salaries paid by enterprises, as well as taxes on capital existing taxes to which this Agreement shall apply are: the case of Georgia:

(i) profit tax;

(ii) income tax;

(iii) property tax; (hereinafter referred to as "Georgian tax"); the case of Malta: income tax; (hereinafter referred to as "Malta tax").

Agreement shall apply also to any identical or substantially similar imposed after the date of signature of this Agreement in addition to, the existing taxes. The competent authorities of the Contracting States each other of any significant changes which have been made in their taxation laws.

Article 3 GENERAL DEFINITIONS purposes of this Agreement, unless the context otherwise requires:

(a) the term "Georgia" means the territory defined by Georgian including land territory, its subsoil and the air space above waters and territorial sea, the sea bed, its sub-soil and above them, in respect of which Georgia exercises its jurisdiction sovereignty, as well as the contiguous zone, the exclusive zone and continental shelf adjacent to its territorial sea, which Georgia may exercise its sovereign rights and accordance with the international law;

(b) the term "Malta" means the Republic of Malta and, when geographical sense, means the Island of Malta, the Island the other islands of the Maltese archipelago including waters thereof, as well as any area of the sea-bed, its sub-soil superjacent water column adjacent to the territorial waters, Malta exercises sovereign rights, jurisdiction, or control with international law and its national law, including relating to the exploration of the continental shelf and exploitation natural resources;

(c) the terms "a Contracting State" and "the other Contracting Malta or Georgia, 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 carried resident of a Contracting State and an enterprise carried on of the other Contracting State;

(g) the term "international traffic" means any transport by a 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 the case of Georgia, the Ministry of Finance or representative;

(ii) in the case of Malta, the Minister responsible for authorised representative;

(i) the term "national" means:

(i) any individual possessing the nationality or citizenship Contracting State;

(ii) any legal person, partnership or association deriving such from the laws in force in a Contracting State.