Double Taxation Relief on Taxes on Income with Romania

L.N. 97 of 2026

INCOME TAX ACT

(CAP. 123)

Double Taxation Relief on Taxes on Income with Romania

(Amendment) Order, 2026

IN EXERCISE of the powers conferred by article 76 of the

Income Tax Act, the Minister responsible for finance, has made the

following order:-

The title of this order is the Double Taxation Relief on Citation.

Taxes on Income with Romania (Amendment) Order, 2026 and this

order shall be read and construed as one with the Double Taxation S.L. 123.42.

Relief on Taxes on Income with Romania Order, hereinafter referred to

as the "principal order".

PROTOCOL AMENDING THE AGREEMENT BETWEEN THE

GOVERNMENT OF MALTA AND THE GOVERNMENT OF

ROMANIA FOR THE AVOIDANCE OF DOUBLE TAXATION

AND THE PREVENTION OF FISCAL EVASION WITH RESPECT

TO TAXES ON INCOME, SIGNED AT BUCHAREST ON 30

NOVEMBER 1995

The Government of Malta and the Government of Romania

Desiring to amend the Agreement between the Government of

Malta and the Government of Romania for the avoidance of double

taxation and the prevention of fiscal evasion with respect to taxes on

income, signed at Bucharest on 30 November 1995 (hereinafter

referred to as "the Agreement"),

Have agreed as follows

ARTICLE I

The text of paragraph 2 of Article 26 of the Agreement is deleted

and replaced by the following

"2. The competent authority shall endeavour, if the

objection appears to it to be justified and if it is not itself able to

arrive at a satisfactory solution, to resolve the case by mutual

agreement with the competent authority of the other Contracting

State, with a view to the avoidance of taxation which is not in

accordance with the Agreement. Any agreement reached shall be

implemented notwithstanding any time limits in the domestic

law of the Contracting States."

ARTICLE II

1. The Contracting States shall notify each other that the legal

requirements for the entry into force of this Protocol have been

complied with.

2. This Protocol shall enter into force thirty days after the date of

the latter of the notifications referred to in paragraph 1 and its provisions shall

have effect in respect of taxes on income derived during any calendar year or

accounting period, as the case may be, beginning on or after the first day of

January immediately following the date on which the Protocol enters into

force.

ARTICLE III

This Protocol shall form an integral part of the Agreement, shall

remain in force as long as the Agreement remains in force and shall

apply as long as the Agreement is applicable.

IN WITNESS WHEREOF, the undersigned, duly authorised

thereto, have signed this Protocol.

Done in duplicate at Bucharest, on 4th July 2024, in the English

and Romanian languages, all texts being equally authentic. In case of

any divergence of interpretation, the English text shall prevail.

For the Government of Malta

For the Government of Romania

Ian Borg

Luminita-Teodora Odobescu

€0.27

It is hereby declared

Coming into

force of

amendments.

(a) that the amendments to the principal order, as

specified in accordance with the Protocol in the Schedule to this

order (hereinafter referred to as the "Protocol"), have been made

with the Government of Romania;

(b) that it is expedient that the said amendments shall

have effect following the entry into force of the Protocol and in

accordance with the relevant provisions of the Protocol;

(c) that the Protocol shall enter into force on such date as

may be established by notice in the Gazette.