S.L. 123.151 Art. 2Arragements to have effect. THE DESIRING prevention of HAVE This Contracting 1. This Mexico and on 2. There income or on movable or 3. The a) in b) in 4. The taxes that are in place of, the shall notify taxation laws. 1. For the a) as and the inland with the rights of seabed, sub- the national inter

It is hereby declared:

(a) that the arrangements specified in the Convention set out in the Schedule to this Order (hereinafter referred to as "the Convention") have been made with the United Mexican States with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of the United Mexican States:

(i) the federal income tax;

(ii) the business flat rate tax;

(b) that it is expedient that those arrangements should have effect following the entry into force of the Convention and in accordance with the relevant provisions of the Convention;

(c) that the Convention shall enter into force on such date as may be announced by notice in the Gazette*.

*9th August, 2014 - see Legal Notice 332 of 2014. SCHEDULE

Article 2 CONVENTION BETWEEN THE UNITED MEXICAN STATES AND MALTA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME UNITED MEXICAN STATES and MALTA, to conclude a Convention for the avoidance of double taxation and the fiscal evasion with respect to taxes on income, 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 behalf of Malta, 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.

existing taxes to which the Convention shall apply are in particular: Mexico: the federal income tax; and the business flat rate tax; (hereinafter referred to as "Mexican tax"); 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 that have been made in their

ARTICLE 3 GENERAL DEFINITIONS purposes of this Convention, unless the context otherwise requires:

the term "Mexico" means the United Mexican States, when used in a geographical sense, includes the territory of the United Mexican States, well as the integrated parts of the Federation, the islands, including the reefs and cays in the adjacent waters, the islands of Guadalupe and Revillagigedo, the continental shelf and the seabed and sub-soil of the islands, cays and reefs, the waters of the territorial seas waters and beyond them the areas over which, in accordance international law, Mexico may exercise its sovereign exploration and exploitation of the natural resources of the soil and the supra-jacent waters, and the air space of territory to the extent and under conditions established by 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 Mexico or Malta, 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 term "enterprise" applies to the carrying on of any business; g) 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; h) the term "international traffic" means any transport by a operated by a resident of a Contracting State, except when aircraft is operated solely between places in the other Contracting i) the term "business" includes the performance of professional and of other activities of an independent character; j) the term "competent authority" means:

(i) in Mexico, the Ministry of Finance and Public Credit;

(ii) in Malta, the Minister responsible for finance or representative; k) 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.