A double tax agreement (DTA) between the Government of Malta and the Norwegian Government, signed on 30 March 2012, entered into force on 14 February 2013. New provision will come into application from 1 January, 2014 and these will replace the old treaty provisions.
Under the treaty the definition of permanent establishment includes the provision of services in the other contracting state by employees or other staff engaged for the purpose.
The treaty also contains an Article in respect of offshore activities. A person carrying on activities offshore in the other contracting state in connection with the exploration or exploitation of the seabed or subsoil is deemed to be carrying on a business in the other state through a permanent establishment, unless the activities continue for a period less than thirty days in a twelve month period.
Moreover, this treaty provides Articles regarding` Dividends, Interest and Royalties.
