Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta) and are to be read in, drawn up, executed and given effect to. 2.5 Nexus with Malta Irrespective of the tax residency of, satisfy at least one of the following conditions: • it is resident for tax purposes in Malta, in Malta for tax purposes but has a permanent establishment herein it will only need to consider, Trustee, the Trust will be considered to be resident in Malta for tax purposes. 2.6 Professional

.......................................... 28 5.4 Profit (Loss) before Income Tax ............................................................................................ 28 5.5 Amount of Income Tax Accrued, in practices that have the effect of artificially shifting substantial amounts of income into tax, business the amount of revenue, profit before income tax, taxes and other indicators of economic, Guidelines These guidelines are issued in terms of Article 96(2) of the Income Tax Act (Chapter 123

Article 96 (2) of the Income Tax Act. Version 4.8 Implementing Guidelines on Automatic Exchange, right to vary its position accordingly. © Malta Tax and Customs Administration Implementing, Compliance Act FATCA Inter- Governmental Agreement IGA Malta Financial Institution MFI Malta Tax, holdable source income. In this regard, on 16th December 2013, Malta concluded a reciprocal Model 1A, on Mutual Administrative Assistance in Tax Matters, an instrument which Malta ratified on 29th May

Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta) and are to be read in, drawn up, executed and given effect to. 2.5 Nexus with Malta Irrespective of the tax residency of, satisfy at least one of the following conditions: • it is resident for tax purposes in Malta; • it, in Malta for tax purposes but has a permanent establishment herein it will only need to consider the, Trustee, the Trust will be considered to be resident in Malta for tax purposes. 2.6 Professional

Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta) and are to be read in, drawn up, executed and given effect to. 2.5 Nexus with Malta Irrespective of the tax residency of, satisfy at least one of the following conditions: • it is resident for tax purposes in Malta; • it, in Malta for tax purposes but has a permanent establishment herein it will only need to consider the, Trustee, the Trust will be considered to be resident in Malta for tax purposes. 2.6 Professional

. (S.L. 123.127 and S.L. 123.156) Issued in terms of Article 96(2) of the Income Tax Act, of Malta’s international commitments to combat cross-border tax fraud and tax evasion. This, U.S. withholdable source income. In this regard, on 16th December 2013, Malta concluded a reciprocal, Convention on Mutual Administrative Assistance in Tax Matters, an instrument which Malta ratified on, with Other Jurisdiction on Tax Matters Regulations provide that: The term “Malta Financial

. (S.L. 123.127 and S.L. 123.156) Issued in terms of Article 96(2) of the Income Tax Act, of Malta’s international commitments to combat cross-border tax fraud and tax evasion. This, U.S. withholdable source income. In this regard, on 16th December 2013, Malta concluded a reciprocal, Convention on Mutual Administrative Assistance in Tax Matters, an instrument which Malta ratified on, Institution’ if Malta is the jurisdiction of its tax residence and in the case of FATCA also where the FI

. (S.L. 123.127 and S.L. 123.156) Issued in terms of Article 96(2) of the Income Tax Act, of Malta’s international commitments to combat cross-border tax fraud and tax evasion. This, U.S. withholdable source income. In this regard, on 16th December 2013, Malta concluded a reciprocal, Convention on Mutual Administrative Assistance in Tax Matters, an instrument which Malta ratified on, trustees are resident in Malta for tax purposes then the trust is to be considered as Malta resident

. (S.L. 123.127 and S.L. 123.156) Issued in terms of Article 96(2) of the Income Tax Act, of Malta’s international commitments to combat cross-border tax fraud and tax evasion. This, U.S. withholdable source income. In this regard, on 16th December 2013, Malta concluded a reciprocal, Convention on Mutual Administrative Assistance in Tax Matters, an instrument which Malta ratified on, with Other Jurisdiction on Tax Matters Regulations provide that: The term “Malta Financial