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Hong Kong And Malta To Discuss DTA

by Mary Swire,, Hong Kong

25 January 2010

Malta and Hong Kong have been holding preliminary meetings on a bilateral double taxation agreement (DTA), in preparation for technical discussions scheduled to commence in March this year.

Malta’s Parliamentary Secretary for Revenues and Land, Jason Azzopardi, has been holding meetings in Hong Kong on such an agreement, which would be the first DTA entered into by Hong Kong with a country in the south of Europe.

Malta will therefore hope to gain from a DTA with Hong Kong, not only because the latter is a major and developing financial and investment center in Asia, but also because it may become a staging point for Hong Kong into its neighbors in southern Europe and North Africa.

Until June 2001, Hong Kong had no DTAs in place. However, its government is now entering an increasing number of tax treaties of various types. It can now negotiate its own DTAs independently of China. It is not able to take advantage of any DTAs which China may enter into because only mainland taxes are mentioned in those treaties.

Malta itself has entered into more than 50 DTAs, including with the United Kingdom, Australia, Canada, France, Germany and Italy. All of these agreements follow the Organization for Economic Cooperation and Development model tax treaty convention. No details are yet available of the terms and conditions of the proposed DTA with Hong Kong.

A comprehensive report in our Intelligence Report series giving a country-by-country analysis of offshore investment funds, stock exchanges and trusts, with an analysis of the US QI regime, is available in the Lowtax Library at and a description of the report can be seen at

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