2 April 2012 Details of the Hong Kong - Malta Income Tax Agreement (2011) and protocol, signed on 8 November 2011, have become available. The agreement was concluded in the English language. The treaty generally follows the OECD Model Convention. The maximum rates of withholding tax are: -   0% on dividends; -   0% on interest; -   3% on royalties. Deviations from the OECD Model include that: -   the term permanent establishment (PE) includes the furnishing of services, including consultancy services, by an enterprise directly or through employees or other personnel engaged by the enterprise for such...