The Government of Malta and the Government of the United Arab Emirates, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed as follows:
This Convention shall apply to persons who are residents of one or both of the Contracting States.
1. This Convention shall apply to taxes on income imposed by a Contracting State, irrespective of the manner in which they are levied.
2. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property and taxes on the total amounts of wages or salaries paid by enterprises.
3. The existing taxes to which this Convention shall apply are:
a. in Malta:
the income tax;
(hereinafter referred to as "Malta tax").
b. in the United Arab Emirates:
i. income tax; and
ii. corporation tax;
(hereinafter referred to as "U.A.E. tax").