S.L. 123.143 Art. 2Arragements to have effect. The Agreement for with respect to This Parties. 1. This irrespective of 2. There income, or on movable or paid by 3. The (a) in (b) in the 4. The taxes that are in place of, the each other of which may affect 1. For the (a) the law; (b) the in accordance its legislation e

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 States of Guernsey with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of The States of Guernsey: - income tax;

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

(c) that the Convention has entered into force on the 10 March 2013.

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

Article 1 PERSONS COVERED Agreement shall apply to persons who are residents of one or both of the

Article 2

TAXES COVERED Agreement shall apply to taxes on income imposed on behalf of a Party, 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 in particular:

the case of Guernsey: income tax; (hereinafter referred to as "Guernsey 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 the Agreement in addition to, or existing taxes. The competent authorities of the Parties shall notify any significant changes that have been made in their taxation laws matters covered by the Agreement. Article 3 GENERAL DEFINITIONS

purposes of this Agreement, unless the context otherwise requires: term "Guernsey" means the States of Guernsey and, when used in a geographical sense, means Guernsey, Alderney and Herm, including the territorial sea adjacent to those islands, in accordance with international term "Malta" means the Republic of Malta and, when used in a 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 term "collective investment scheme" means any pooled vehicle, irrespective of legal form;

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

(e) the term "competent authority" means:

(i) in the case of Guernsey, the Director of Income delegate;

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

(f) the terms "enterprise of a Party" and "enterprise of mean respectively an enterprise carried on by a resident an enterprise carried on by a resident of the other Party;

(g) the term "international traffic" means any transport by operated by an enterprise of a Party, except when the operated solely between places in the other Party;

(h) the term "national", in relation to a Party, means:

(i) in the case of Guernsey, any individual who Guernsey and possesses British citizenship, any created or organised under the laws of Guernsey organisation without legal personality treated for Guernsey tax as a legal person created or organised laws of Guernsey;

(ii) in the case of Malta:

(a) any individual possessing the nationality of

(b) any legal person, partnership or association status as such from the laws in force in Malta;

(i) the terms "a Party" and "the other Party" mean Guernsey the context requires;

(j) the term "person" includes an individual, a collective scheme, a company and any other body of persons.