Tax Treaty Between Malta And Moldova

Details of the Malta – Moldova Income Tax Treaty (2014), signed on 10 April 2014 have become available. The treaty generally follows the OECD Model, with some deviations, including the following:

• a building site, a construction, assembly or installation project, or supervisory activities in connection therewith constitute a permanent establishment (PE) only if such site, project or activities last for more than 12 months; and

• article 7 of the treaty follows the article on business profits of the UN Model (2001). Additionally, it provides that no profits shall be attributed to a PE by reason of the mere purchase by that PE of goods or merchandise for the enterprise (article 7(5)).