Dividends: 5% WHT remains available for dividends distributed to the Government, its subdivisions, insurance companies and pension funds.
For business-related cases, 5% WHT applies to distributions to companies listed on recognized stock exchange with at least 15% free float and holding at least 15% shares of the distributing company for at least 365 days.
Interest: 5% WHT will apply to interest on bank loans, corporate bonds and eurobonds paid to companies tax residents in Malta. It is worth noting that interest on eurobonds is tax exempt in Russia under domestic law.
5% WHT on interest is higher than zero WHT rate agreed under the Protocol with Cyprus, however current Russia Malta DTT also provides with 5% WHT on interest, therefore WHT rate for qualifying interest did not increase.
It has been reported that similar changes have been agreed during the re- negotiations of DTTs with Luxembourg. Negotiations with the Netherlands continue.
