S.L. 123.132 Art. 2Arrangements to have effect. The desiring to prevention of This Contracting 1. This Contracting the manner in 2. There income, or on movable or paid by The existing (a) in (b) in 4. The taxes that are in place of, the shall notify respective 1. For the (a) used in a of Gozo and the territorial and t

It is hereby declared:

(a) that the arrangements specified in the Convention set out in the Schedule to this Order have been made with the Government of the Kingdom of Bahrain with a view to affording relief from double taxation in relation to the following tax imposed by the laws of the Kingdom of Bahrain: - income tax payable under Amiri Decree No. 22/ 1979;

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

(c) that the Convention has entered into force on the 28 February 2012. SCHEDULE (Article 2)

CONVENTION BETWEEN THE GOVERNMENT OF MALTA AND THE GOVERNMENT OF THE KINGDOM OF BAHRAIN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Government of the Kingdom of Bahrain and the Government of Malta, conclude a Convention for the avoidance of double taxation and the fiscal evasion with respect to 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 on behalf of a State or of its political subdivisions or local authorities, irrespective of 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 and taxes on the total amounts of wages or salaries enterprises. taxes to which this Convention shall apply are in particular: Bahrain: income tax payable under Amiri Decree No. 22/1979) (hereinafter referred to as "Bahrain tax"); and Malta: the 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, or 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 Convention, unless the context otherwise requires: the term "Bahrain" means the territory of the Kingdom of Bahrain as well as the maritime areas, seabed and subsoil over which Bahrain exercises, in accordance with international law, sovereign rights and jurisdiction;

(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 Bahrain or Malta, as the context requires;

(d) the term "person" includes an individual, a company, investment scheme and any other body of persons;

(e) the term "company" means any body corporate or any treated as a body corporate for tax purposes or any constituted or recognised under the laws of one or Contracting States as a body corporate;

(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 "business" includes the performance of professional and of other activities of an independent character;

(i) the term "competent authority" means:

(i) in Bahrain: the Minister of Finance or his representatives; and

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

(j) the term "national", in relation to a Contracting State, means:

(i) any individual possessing the nationality of that State;

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