S.L. 123.43 Art. 2Arrangements to hove effect. Malta and avoidance of taxes on This Contracting 1. This behalf of a irrespective of 2. There on total taxes on gains total amounts appreciation. 3. The (a) in (b) in 4. The taxes which or in place of, shall notify respective 5. not apply to article (13) of any person su

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 Czech Republic with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of the Czech Republic:

(i) the tax on income of individuals;

(ii) the tax on income of legal persons;

(iii) the tax on immovable property;

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

CONVENTION BETWEEN MALTA AND THE CZECH REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

the Czech Republic, desiring to conclude a Convention for the double taxation and the prevention of fiscal evasion with respect to income and on capital, have agreed as follows:

ARTICLE 1

Personal Scope Convention shall apply to persons who are resident of one or both of the States.

ARTICLE 2

Taxes Covered

Convention shall apply to taxes on income and on capital imposed on Contracting State or of its political subdivisions or local authorities, the manner in which they are levied. shall be regarded as taxes on income and on capital all taxes imposed income, on total capital, or on elements of income or of capital including from the alienation of movable or immovable property, taxes on the of wages or salaries paid by enterprises, as well as taxes on capital existing taxes to which the Convention shall apply are:

the Czech Republic:

(i) the tax on income of individuals;

(ii) the tax on income of legal persons;

(iii) the tax on immovable property; (hereinafter referred to as "Czech tax"); Malta: the income tax; (hereinafter refereed to as "Malta tax"). Convention shall apply also to any identical or substantially similar are imposed after the date of signature of the Convention in addition to, the existing taxes. The competent authorities of the Contracting States each other of any significant changes which have been made in their taxation laws. Notwithstanding the other provisions of this Article, this Convention shall tax paid or payable in Malta in accordance with the provisions of sub-article 56 of the Income Tax Act, concerning the chargeable income of engaged in the production of petroleum produced in Malta or any similar provision which is imposed after the date of signature of this

ARTICLE 3

General Definitions For the purposes of this Convention, unless the context otherwise requires:

(a) the term "Czech Republic", when used in a geographical sense, territory over which the Czech Republic, under the Czech legislation accordance with international law, may exercise its sovereign rights;

(b) the term "Malta" means the Republic of Malta and, when geographical sense, means the Island of Malta, the Island of Gozo islands of the Maltese Archipelago including the territorial waters thereof, area outside the territorial waters of Malta which has been or may designated, in accordance with international law and under the concerning the continental shelf, as an area within which the rights respect to the seabed and subsoil and their natural resources may be exercised;

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

(d) the term "person" includes an individual, a company and any persons;

(e) the term "company" means any body corporate or any entity which as a body corporate for tax purposes;

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

(g) the term "national" means:

(i) any individual possessing the nationality of a Contracting

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

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

(i) the term "competent authority" means:

(i) in the case of the Czech Republic, the Minister of authorized representative;

(ii) in the case of Malta, the Minister responsible for authorized representative.