Details of the income tax treaty and protocol between Jersey and Malta, signed on 25 January 2010, have become available. The treaty was concluded in the English language. The treaty follows the OECD Model Convention, with certain deviations as described below. Regarding dividends, the treaty provides for the right to tax for the recipient's state of residence. However, as long as Malta operates a full imputation system in respect to the taxation of the company profits, outbound dividend paid to a beneficial owner in Jersey, may be taxed in Malta, but such tax cannot exceed that chargeable on the profits...