S.L. 123.63 Art. 2Arrangements to have effect.

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

(i) the personal income tax (Imposto sobre o Rendimento das Pessoas Singulares - IRS);

(ii) the corporate income tax (Imposto sobre o Rendimento das Pessoas Colectivas - IRC); and

(iii) the local surtax on corporate income tax (Derrama);

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

(c) that the Convention has entered into force on the 5th April, 2002. SCHEDULE

CONVENTION BETWEEN MALTA AND THE PORTUGUESE REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Government of Malta and the Government of the Portuguese Republic, conclude a Convention for the Avoidance of Double Taxation and the Fiscal Evasion with respect to Taxes on Income, have agreed as

CHAPTER I

SCOPE OF THE CONVENTION Article 1 PERSONAL SCOPE

Convention shall apply to persons who are residents of one or both of Contracting States.

Article 2 TAXES COVERED Convention shall apply to taxes on income imposed on behalf of a State or its political or 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, taxes on the total amounts of wages or salaries paid as well as taxes on capital appreciation. existing taxes to which the Convention shall apply are in particular:

the case of Portugal:

(i) the personal income tax (Imposto sobre o Rendimento das Pessoas Singulares - IRS);

(ii) the corporate income tax (Imposto sobre o Rendimento das Pessoas Colectivas - IRC); and

(iii) the local surtax on corporate income tax (Derrama); (hereinafter referred to as "Portuguese tax"); the case of Malta: the income tax; (hereinafter referred 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 notify each other of substantial changes which have been made in their taxation laws. CHAPTER II DEFINITIONS

Article 3 GENERAL DEFINITIONS