S.L. 123.166 ст. 2Arrangements to have effect. The and the Kingdom Desiring to prevention of Have agreed This Contracting 1. This Contracting the manner in 2. There income, or on movable or paid by 3. The (a) in (b) in

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 Kingdom of the Netherlands, in respect of Curaçao with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of Curaçao: - the income tax (inkomstenbelasting); - the wage tax (loonbelasting); - the profit tax (winstbelasting); - the dividend tax (dividendbelasting);

(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 has entered into force on 1st September 2024. SCHEDULE

Article 2 CONVENTION BETWEEN THE REPUBLIC OF MALTA AND THE KINGDOM OF THE NETHERLANDS, IN RESPECT OF CURAÇAO, FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Republic of Malta of the Netherlands, in respect of Curaçao, conclude a Convention for the avoidance of double taxation and the fiscal evasion with respect to taxes on income, as follows:

CHAPTER 1 Scope of the Convention

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 a State 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 the Convention shall apply are in particular: the case of Malta: the income tax; (hereinafter referred to as "Malta tax"); the case of Curaçao: - the income tax (inkomstenbelasting); - the wage tax (loonbelasting); - the profit tax (winstbelasting); - the dividend tax (dividendbelasting); (hereinafter referred to as "Curaçao tax").