S.L. 123.161 Art. 2Arragements to have effect. THE The Mauritius, and the follows: This Contracting 1. This Contracting State the manner in 2. There income, or on movable or paid by 3. The (a) in (b) in 4. The taxes that are in place of, the shall notify each taxation laws. 1. For the (a) the the with the laws which i

It is hereby declared:

(a) that the arrangements specified in the Agreement set out in the Schedule to this Order (hereinafter referred to as "the Agreement") have been made with the Republic of Mauritius with a view to affording relief from double taxation in relation to the following tax imposed by the laws of the Republic of Mauritius: - the income tax;

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

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

*23rd April, 2015 - see Legal Notice 362 of 2015. THE GOVERNMENT OF THE REPUBLIC OF MALTA AND GOVERNMENT OF THE REPUBLIC OF MAURITIUS FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Government of the Republic of Malta and the Government of the Republic of desiring to conclude an agreement for the avoidance of double taxation prevention of fiscal evasion with respect to taxes on income, have agreed as

Article 1

PERSONS COVERED Agreement shall apply to persons who are residents of one or both of the States. Article 2 TAXES COVERED

Agreement shall apply to taxes on income imposed on behalf of a 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.

existing taxes to which this Agreement shall apply are in particular: Malta, the income tax, (hereinafter referred to as "Malta tax"); Mauritius, the income tax, (hereinafter referred to as "Mauritius 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 Contracting States other of any significant changes that have been made in their

Article 3

GENERAL DEFINITIONS purposes of this Agreement, 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

(i) all the territories and islands which, in accordance of Mauritius, constitute the State of Mauritius;

(ii) the territorial sea of Mauritius; and

(iii) any area outside the territorial sea of Mauritius accordance with international law has been or designated, under the laws of Mauritius, as an area, Continental Shelf, within which the rights of respect to the sea, the sea-bed and sub-soil resources may be exercised;

(c) the terms "a Contracting State" and "the other Contracting Malta or Mauritius, as the context requires;

(d) the term "person" includes an individual, a collective scheme, a company, a trust and any other body of treated as an entity for tax purposes;

(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, 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 Malta, the Minister responsible for finance or

(ii) in Mauritius, the Minister to whom responsibility of finance is assigned or his authorised representative;

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

(i) any individual possessing the nationality or citizenship Contracting State;

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

(k) the term "tax" means Malta tax or Mauritius tax, as the