S.L. 123.95 ст. 2Arrangements to have effect. The Convention for with respect to This Contracting 1. This Contracting State are levied. 2. There income, or on movable or by enterprises, 3. The a) In (i) (ii) b) In the 4. The taxes that are in place of, the shall notify each respective 1. For the (a) the subsoil and

It is hereby declared -

(a) that the arrangements specified in the Convention set out in the Schedule to this Order have been made with Iceland with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of Iceland:

(i) the income taxes to the state (tekjuskattar ríkissjóðs); and

(ii) the income tax to the municipalities (útsvar sveitarfélaga);

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

(c) that the Convention has entered into force on the 19th April, 2006. FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Government of Iceland and the Government of Malta, desiring to conclude a the avoidance of double taxation and the prevention of fiscal evasion taxes on income, have agreed as follows:

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 or of its local authorities, irrespective of the manner in which they 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: Iceland: the income taxes to the state (tekjuskattar ríkissjóðs); and the income tax to the municipalities (útsvar sveitarfélaga), (hereinafter referred to as "Icelandic tax"); Malta: income tax (hereinafter referred to as "Malta tax"). Convention shall apply also to any identical or substantially similar imposed after the date of signature of the Convention in addition to, or existing taxes. The competent authorities of the Contracting States other of any significant changes that have been made in their taxation laws. Article 3

GENERAL DEFINITIONS purposes of this Convention, unless the context otherwise requires: term "Iceland" means the Republic of Iceland and, when used in a geographical sense, means the territory of the Republic of Iceland, including its territorial sea, and any area beyond the territorial sea within which Iceland, in accordance with international law, exercises jurisdiction or sovereign rights with respect to the seabed, its subsoil waters thereof, as well as any area of the seabed, its superjacent water column adjacent to the territorial Malta exercises sovereign rights, jurisdiction or control with international law and its national law, including relating to the exploration of the continental shelf and natural resources;

(c) the term "person" includes an individual, a company and of persons;

(d) the term "company" means any body corporate or any treated as a body corporate for tax purposes;

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

(f) the terms "a Contracting State" and "the other Contracting Iceland or Malta as the context requires;

(g) the term "international traffic" means any transport by 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 the case of Iceland, the Minister of Finance representative;

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