DOUBLE TAXATION RELIEF ON SHIPS AND AIRCRAFT
WITH THE SWISS FEDERATION ġ S.L.123.18 1
SUBSIDIARY LEGISLATION 123.18
DOUBLE TAXATION RELIEF ON SHIPS AND 
AIRCRAFT WITH THE SWISS FEDERATION 
ORDER
30th March, 1987
 LEGAL NOTICE 31 of 1988.
Title.
and Aircraft with the Swiss Federation Order.
Taxes covered.
( a ) the Schedule to this Order has been agreed and made
with the Swiss Federal Council with a view to
affording relief from double taxation in relation to the
taxation of shipping and aviation companies in Malta
and in Switzerland, hereinafter referred to as "a
Contracting State" and "the other Contracting State" as
the context requires; and
( b ) reference to the tax levied in Switzerland includes
federal, cantonal and communal tax.
2 ġ S.L.123.18
DOUBLE TAXATION RELIEF ON SHIPS AND AIRCRAFT
WITH THE SWISS FEDERATION
SCHEDULE
AGREEMENT BETWEEN 
THE SWISS FEDERAL COUNCIL 
AND 
THE GOVERNMENT OF THE REPUBLIC OF MALTA
1. Profits derived by an enterprise of a Contracting State from the operation of
ships or aircraft in international traffic shall be exempt from any tax on income or on
profits in the other Contracting State. This exemption shall also apply to profits from
the participation in a pool, a joint business or an international operating agency.
2. Capital of an enterprise of a Contracting State represented by ships and
aircraft and by movable property pertaining to the operation of such ships and
aircraft in international traffic shall be exempt from any tax on capital in the other
Contracting State.
3. The term "enterprise of a Contracting State" means an enterprise which is
effectively managed and controlled in that State. The term shall be deemed to
include any enterprise in which the Contracting State has a share or which is carried
on by the Contracting State.
4. The term "operation of ships or aircraft" means the business of transporting
persons or cargo by the owner, hirer or charterer of ships or aircraft.
5. The term "international traffic" means any transport by a ship or aircraft
operated by an enterprise of a Contracting State except when the ship or aircraft is
operated solely between places in the other Contracting State.
6. The exemption provided for in paragraphs 1 and 2 hereof shall be granted
with respect to any tax levied in either Contracting State for any year of assessment
beginning after 31st December, 1977.
7. Each Contracting State reserves the right to withdraw the present declaration
at the end of a calendar year after six months’ prior notice; in such an event the
exemption provided for in paragraphs 1 and 2 shall apply for the last time to any tax
levied in either Contracting State for the year of assessment commencing on 1st
January of the year immediately following that calendar year.
