Malta has introduced changes to its long-standing double taxation agreement with Romania through the Double Taxation Relief on Taxes on Income with Romania (Amendment) Order, 2026 (L.N. 97 of 2026), published in the Government Gazette earlier this month.
The legal notice gives effect to a protocol signed in Bucharest on 4 July 2024, marking the first amendment to the bilateral tax treaty originally concluded in 1995.
At the core of the amendment is a revision to the mutual agreement procedure between the two countries’ tax authorities. The updated provision requires competent authorities to seek resolution of cross-border tax disputes through mutual agreement, aimed at strengthening dispute resolution and reducing cases of double taxation.
The protocol will enter into force once both Malta and Romania complete their legal notification procedures, with its provisions applying to income earned from the start of the calendar year following its entry into force.
The amendment forms part of Malta’s broader network of double taxation treaties, which are designed to prevent the same income from being taxed in multiple jurisdictions and to facilitate cross-border trade and investment.
Disclaimer
The above does not constitute tax or legal advice and is up to date on the date it was published. Please ensure that you take appropriate advice from tax or legal professionals before making any decisions based on the above.
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