S.L. 123.77 Art. 9of the law of a insurance. 1. Profits ships, aircraft Contracting 2. The resident of a international 1. Where (a) an (b) and in either their between conditions, have not so accordingly. 2. Where of that the other and the profits the enterprises enterprises, to the amount adjustment, the competent ot

The provisions of this Article shall not affect the provisions Contracting State regarding the taxation of profits from the business of Article 8 INTERNATIONAL TRAFFIC

derived by a resident of a Contracting State from the operation of or road vehicles in international traffic shall be taxable only in that State. provisions of paragraph 1 shall also apply to profits derived by a Contracting State from the participation in a pool, a joint business or an operating agency. Article 9 ASSOCIATED ENTERPRISES

-enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, case conditions are made or imposed between the two enterprises in commercial or financial relations which differ from those which would be made independent enterprises, then any profits which would, but for those have accrued to one of the enterprises, but, by reason of those conditions, accrued, may be included in the profits of that enterprise and taxed one of the Contracting States includes in the profits of an enterprise Contracting State - and taxes accordingly - profits on which an enterprise of Contracting State has been charged to tax in that other Contracting State so included are profits which would have accrued to the enterprise of first-mentioned Contracting State if the conditions made between the two had been those which would have been made between independent then that other Contracting State shall make an appropriate adjustment of the tax charged therein on those profits. In determining such due regard shall be had to the other provisions of this Convention and authorities of the Contracting States shall, if necessary, consult each

Article 10 DIVIDENDS Dividends paid by a company which is a resident of a Contracting State to a other Contracting State may be taxed in that other Contracting State.

dividends are paid by a company resident of Kuwait to a resident of Malta who is the beneficial owner thereof, no Kuwaiti tax shall be charged on such dividend; dividends are paid by a company which is a resident of Malta to a resident of Kuwait who is the beneficial owner thereof, Malta tax on the gross amount of the dividends shall in no case exceed that chargeable on the profits out of which the dividends are paidg provided, however, that such tax on the gross amount of dividends payable to the Government of Kuwait or any of its institutions or any inter-governmental referred to in paragraph 2 of Article 4 shall not exceed (10%), and that in all other cases such tax shall not exceed cent (15%) of the gross amount of the dividends.