America and Malta have signed a new income tax treaty which provides for reduced withholding rates on cross-border dividend payments generally with the elimination of withholding on cross-border dividend payments to pension funds. It also provides for withholding at a 10% rate on interest, royalties, and other income.
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Pillar two might be top of mind for many multinational companies, but the huge variations between countries’ readiness means getting ahead of the game now, argues Russell Gammon, chief solutions officer at Tax Systems.