This session concerns methods for the relief of double taxation in Maltese law. Specifically, the session shall delve into the following aspects of the subject:

  • Economic double taxation (EDT) relief:
    • Rationale & types of EDT relief;
    • EDT relief mechanisms in the ITA;
      • The full imputation system (article 31, 59 and 60 of the ITA);
      • The participation exemption (as relevant for the relief of EDT); and
      • The indirect foreign tax credit.
    • Juridical double taxation relief:
      • Rationale & types of JDT relief;
      • Outbound considerations:
        • Ordinary direct foreign tax credit system;
          • Treaty relief;
          • Unilateral relief;
        • Commonwealth relief;
        • Flat-rate foreign tax credit.
        • The participation exemption (as relevant for the relief of JDT).
      • Inbound considerations:
        • Source rules;
        • Treaty relief as applicable to Malta as the ‘other Contracting State’.
      • Miscellaneous issues:
        • Switch-over clauses;
        • Anti-hybrid rules;
        • Subject-to-tax rules.
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Christopher Bergedahl is a Senior Manager within Deloitte’s Tax & Legal Business in Malta. He provides support on both local and foreign client engagements within the International Tax service line, with a focus on US-based multinational enterprise clients and the financial services sector.

Christopher joined Deloitte Malta in 2014, having enrolled in the Deloitte Pathway Programme. In 2017, he graduated summa cum laude from the International Tax Center Leiden, following which he worked as a Teaching Assistant for the Fall Term of the 2017-18 class. In 2019, Christopher placed first overall in the 2018-19 class of the MIT Course on Taxation. He is a member of the Malta Institute of Taxation, the International Fiscal Association and the Institute of Financial Services Practitioners.

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