S.L. 123.135 Art. 2Arrangements to have effect. GOVERNMENT THE TAXATION The Administrative Desiring to prevention of Have agreed as This Contracting 1. This Contracting Party, 2. There income, or on movable or paid by 3. The (a) in the (i) (ii) (iii) whether (b) in the the 4. The taxes that are in place of, the and 2

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 The Hong Kong Special Administrative Region of the People’s Republic of China with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of The Hong Kong Special Administrative Region of the People’s Republic of China:

(i) profits tax;

(ii) salaries tax; and

(iii) property tax

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

(c) that the Agreement has entered into force on the 18th July, 2012. AGREEMENT BETWEEN THE GOVERNMENT OF MALTA AND THE OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION OF PEOPLE’S REPUBLIC OF CHINA FOR THE AVOIDANCE OF DOUBLE AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Government of Malta and the Government of the Hong Kong Special Region of the People’s Republic of China, conclude an Agreement for the avoidance of double taxation and the fiscal evasion with respect to taxes on income, follows: Article 1

Persons Covered Agreement shall apply to persons who are residents of one or both of the Parties. Article 2 Taxes Covered

Agreement shall apply to taxes on income imposed on behalf of a 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 and taxes on the total amounts of wages or salaries enterprises. existing taxes to which the Agreement shall apply are: case of the Hong Kong Special Administrative Region, profits tax; salaries tax; and property tax; or not charged under personal assessment; case of Malta, income tax.

Agreement shall apply also to any identical or substantially similar imposed after the date of signature of the Agreement in addition to, or existing taxes, as well as any other taxes falling within paragraphs 1 Article which a Contracting Party may impose in future. The competent Contracting Parties shall notify each other of any significant been made in their taxation laws. existing taxes, together with the taxes imposed after the signature of the hereinafter referred to as "Hong Kong Special Administrative "Malta tax", as the context requires.

(a) (i) the term "Hong Kong Special Administrative Region" territory where the tax laws of the Hong Administrative Region of the People’s Republic

(ii) the term "Malta" means the Republic of Malta and, geographical sense, means the Island of Malta, the and the other islands of the Maltese archipelago territorial waters thereof, as well as any area of sub-soil and the superjacent water column territorial waters, wherein Malta exercises jurisdiction, or control in accordance with international its national law, including its legislation exploration of the continental shelf and exploitation resources;

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

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

(d) the term "competent authority" means:

(i) in the case of the Hong Kong Special Administrative Commissioner of Inland Revenue or his authorised

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

(e) the terms "Contracting Party" and "Party" mean the Hong Administrative Region or Malta, as the context requires;

(f) the term "enterprise" applies to the carrying on of any

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

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

(i) the term "national", in relation to Malta, means:

(i) any individual possessing the nationality of Malta;

(ii) any legal person, partnership or association deriving such from the laws in force in Malta;

(j) the term "person" includes an individual, a partnership, any other body of persons;

(k) the term "tax" means Hong Kong Special Administrative Malta tax, as the context requires.