The Inland Revenue Board of Malaysia (IRBM) has published the synthesized text of the Malaysia-Malta double taxation agreement as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
The document was prepared on the basis of the reservations and notifications submitted to the MLI Depositary by both countries. It presents the treaty as modified by whichever MLI provisions each jurisdiction has opted into, allowing practitioners to read the combined effect in a single text. The IRBM has confirmed that the authentic legal texts of the underlying treaty and the MLI itself take precedence and remain the operative legal instruments.
Practitioners advising on Malaysia-Malta cross-border structures should treat the synthesized text as a practical working tool. Where any question of interpretation arises, the original treaty and the MLI convention text govern.