S.L. 123.138 Art. 2Arrangements to have effect. THE FOR THE TAX The desiring to prevention of tax This Contracting 1. This Contracting irrespective of 2. There income, or on movable or paid by 3. The (a) in the (b) in - the - the 4. The substantially date of signature The competent significant 1. For the (a) the the 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 Saudi Arabia with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of The Kingdom of Saudi Arabia:

(i) the Zakat; and

(ii) the natural gas investment tax;

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

(c) that the Convention has entered into force on 1st December 2012. GOVERNMENT OF THE KINGDOM OF SAUDI ARABIA AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF EVASION WITH RESPECT TO TAXES ON INCOME Government of Malta and the Government of the Kingdom of Saudi Arabia, conclude a Convention for the avoidance of double taxation and the 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 administrative subdivisions or local authorities, 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 this Convention shall apply are in particular:

the case of Malta: income tax; (hereinafter referred to as "Malta tax"), the case of the Kingdom of Saudi Arabia: Zakat; income tax including the natural gas investment tax (hereinafter referred to as the "Saudi tax"). provisions of this Convention shall also apply to any identical or similar taxes which are imposed by either Contracting State after the of this Convention in addition to, or in place of, the existing taxes. authorities in both Contracting States shall notify each other of any changes which have been made in their respective taxation laws. Article 3 GENERAL DEFINITIONS

purposes of this Convention, unless the context otherwise requires: term "Malta" means the Republic of Malta and, when used in a geographical sense, means the Island of Malta, the Island of Gozo and other islands of the Maltese archipelago including the territorial waters thereof, as well as any area of the sea-bed, its sub-soil and the superjacent water column adjacent to the territorial waters, wherein Malta exercises sovereign rights, jurisdiction, or control in accordance of Saudi Arabia which also includes the area outside waters, where the Kingdom of Saudi Arabia exercises jurisdictional rights in their waters, sea bed, sub-soil resources by virtue of its law and international law;

(c) the terms "a Contracting State" and "the other Contracting Malta or the Kingdom of Saudi Arabia, as the context

(d) the term "person" includes an individual, a company and of persons including the State and its administrative local authorities;

(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 which effective management in a Contracting State, except aircraft is operated solely between places in the other Contracting

(h) the term "competent authority" means:

(i) in the case of Malta: the Minister responsible for authorised representative;

(ii) in the case of the Kingdom of Saudi Arabia, Finance represented by the Minister of Finance representative;

(i) the term "national" means:

(i) any individual possessing the nationality of a Contracting

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