S.L. 123.152 Art. 2Arragements to have effect. The conclude a fiscal evasion This Contracting 1. This Contracting State the manner in 2. There income, or on movable or paid by 3. The (a) in the (b) in (i) (ii) (iii) 4. The taxes that are in place of, the shall notify each taxation laws. 1. For the waters, wherein in a

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 Government of The State of Israel with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of The State of Israel:

(i) the income tax and company tax (including tax on capital gains);

(ii) the tax imposed on gains from the alienation of property according to the Real Estate Taxation Law; and;

(iii) the profit tax on financial institutions;

(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 shall enter into force on such date as may be announced by notice in the Government Gazette*.

*the Convention came into force on 8th December, 2013 - see L.N. 57 of 2014. BETWEEN THE GOVERNMENT OF MALTA AND THE GOVERNMENT OF THE STATE OF ISRAEL FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

Government of Malta and the Government of the State of Israel desiring to Convention for the avoidance of double taxation and the prevention of with respect to 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 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 this Convention shall apply are in particular: Malta: income tax; (hereinafter referred to as "Malta tax"); Israel: the income tax and company tax (including tax on capital gains); the tax imposed on gains from the alienation of property according to the Real Estate Taxation Law; and the profit tax on financial institutions; (hereinafter referred to as "Israeli 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

Article 3 GENERAL DEFINITIONS

purposes of this Convention, unless the context otherwise requires: 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;

(b) the term "Israel" means the State of Israel and geographical sense comprises the territory in which the the State of Israel has taxation rights, including its well as those maritime areas adjacent to the outer limit sea, including seabed and subsoil thereof over which the in accordance with international law and the laws of the exercises its sovereign or other rights and jurisdiction;

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

(d) the term "person" includes an individual, a company, other body of persons;

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

(f) the term "enterprise" applies to the carrying on of any

(g) 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;

(h) the term "international traffic" means any transport by operated by an enterprise of a Contracting State that effective management in a Contracting State, except aircraft is operated solely between places in the other Contracting

(i) the term "competent authority" means:

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

(ii) in Israel, the Minister of Finance or his authorised

(j) the term "national", in relation to a Contracting State,

(i) any individual possessing the nationality of State;

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

(k) the term "business" includes the performance of professional and of other activities of an independent character.