S.L. 123.67 Art. 2Arrangements to have effect. AND The desiring to prevention of This the 1. This Contracting are levied. 2. There income, or on movable or 3. The (a) in (b) in 4. The taxes which or in place of, shall notify respective 1. For the (a) of (b) of Gozo and the territorial and the wherein the or control i

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 Republic of Estonia with a view to affording relief from double taxation in relation to the following taxes imposed by the laws of the Republic of Estonia: - the income tax (tulumaks);

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

(c) that the Convention has entered into force on the 22nd January, 2003. SCHEDULE CONVENTION BETWEEN THE GOVERNMENT OF MALTA THE GOVERNMENT OF THE REPUBLIC OF ESTONIA 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 Republic of Estonia, conclude a Convention for the avoidance of double taxation and the fiscal evasion 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 Contracting States. Article 2

TAXES COVERED Convention shall apply to taxes on income imposed on behalf of a State 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. existing taxes to which the Convention shall apply are in particular:

Estonia: the income tax (tulumaks); (hereinafter referred to as ''Estonian tax''); Malta: the 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 significant changes which have been made in their taxation laws. Article 3 GENERAL DEFINITIONS

purposes of this Convention, unless the context otherwise requires: the term ''Estonia'' means the Republic of Estonia and, when used in the geographical sense, means the territory of Estonia and any other area adjacent to the territorial waters of Estonia within which under the laws Estonia and in accordance with international law, the rights of Estonia may be exercised with respect to the sea bed and its sub-soil and their natural resources; the term ''Malta'' means the Republic of Malta and, when used in a geographical sense, means the Island of Malta, the Island the other islands of the Maltese archipelago including waters thereof, as well as any area of the sea bed, its sub-soil superjacent water column adjacent to the territorial waters, Republic of Malta exercises sovereign rights, jurisdiction, accordance with international law and its national law, legislation relating to the exploration of the continental exploitation of its natural resources;

(c) the terms ''a Contracting State'' and ''the other Contracting Estonia or Malta, 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 Estonia, the Minister of Finance or his representative;

(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.