S.L. 123.57 ст. 2Arrangements to have effect. The Republic of Taxation and agreed as This the 1. The (a) in (b) in the 2. The taxes which or in place of, shall notify respective 1. For the (a) law; used in a of Gozo and the territorial of Malta with the continental respect to the State'' mean any other bod

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

(i) the tax on income derived from immovable property (including the agriculture land tax and the building tax;

(ii) the unified tax on income of individuals;

(iii) the tax on corporation profits;

(iv) the development duty of the financial resources of the State; and

(v) supplementary taxes imposed as percentage of taxes mentioned above or otherwise;

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

(c) that the Convention has entered into force on the 7th April, 2001. SCHEDULE

CONVENTION BETWEEN THE REPUBLIC OF MALTA AND THE ARAB REPUBLIC OF EGYPT 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 Arab Egypt, desiring to conclude a Convention for the Avoidance of Double the Prevention of Fiscal Evasion with respect to Taxes on Income, have follows: Article 1

PERSONAL SCOPE

Convention shall apply to persons who are residents of one or both of Contracting States. Article 2

TAXES COVERED

existing taxes to which this Convention shall apply are: Egypt:

(i) the tax on income derived from immovable property (including the agriculture land tax and the building tax);

(ii) the unified tax on income of individuals;

(iii) the tax on corporation profits;

(iv) the development duty of the financial resources of the State; and

(v) supplementary taxes imposed as percentage of taxes mentioned above or otherwise; (hereinafter referred to as '' Egyptian tax''); Malta: 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 States each other of any substantial changes which have been made in their taxation laws.

Article 3

GENERAL DEFINITIONS

purposes of this Convention, unless the context otherwise requires: the term ''Egypt'' means the Arab Republic of Egypt and, when used in a geographical sense, means the territory and the territorial waters of the Arab Republic of Egypt and its exclusive economic zone and continental shelf as defined in accordance with international

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

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

(d) the term ''person'' includes an individual, a company and of persons;

(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 carried resident of a Contracting State and an enterprise carried on of the other Contracting State;

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

(h) the term ''competent authority'' means:

(i) in Egypt: the Minister of Finance or his authorised

(ii) in Malta: the Minister responsible for finance or representative;

(i) the term ''national'' means:

(i) any individual possessing the nationality of a Contracting

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