S.L. 123.18 Art. 2Taxes covered. 1. Profits ships or profits in the the 2. Capital aircraft and aircraft in Contracting 3. The effectively include any on by the 4. The persons or 5. The operated by an operated solely 6. The with respect beginning after 7. Each at the end of exemption levied in January of the

It is hereby declared that -

(a) the Schedule to this Order has been agreed and made with the Swiss Federal Council with a view to affording relief from double taxation in relation to the taxation of shipping and aviation companies in Malta and in Switzerland, hereinafter referred to as "a Contracting State" and "the other Contracting State" as the context requires; and

(b) reference to the tax levied in Switzerland includes federal, cantonal and communal tax. SCHEDULE

AGREEMENT BETWEEN THE SWISS FEDERAL COUNCIL AND THE GOVERNMENT OF THE REPUBLIC OF MALTA

derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be exempt from any tax on income or on other Contracting State. This exemption shall also apply to profits from participation in a pool, a joint business or an international operating agency. of an enterprise of a Contracting State represented by ships and by movable property pertaining to the operation of such ships and international traffic shall be exempt from any tax on capital in the other State.

term "enterprise of a Contracting State" means an enterprise which is managed and controlled in that State. The term shall be deemed to enterprise in which the Contracting State has a share or which is carried Contracting State. term "operation of ships or aircraft" means the business of transporting cargo by the owner, hirer or charterer of ships or aircraft. term "international traffic" means any transport by a ship or aircraft enterprise of a Contracting State except when the ship or aircraft is between places in the other Contracting State.

exemption provided for in paragraphs 1 and 2 hereof shall be granted to any tax levied in either Contracting State for any year of assessment 31st December, 1977. Contracting State reserves the right to withdraw the present declaration a calendar year after six months’ prior notice; in such an event the provided for in paragraphs 1 and 2 shall apply for the last time to any tax either Contracting State for the year of assessment commencing on 1st year immediately following that calendar year.