Competent authority arrangement (CAA)
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Competent authority arrangement (CAA)

Publication Date: Dec 22, 2021
The competent authorities of Malta and the United States signed a competent authority arrangement (CAA)​ confirming their understanding of the definition of pension fund for purposes of the Malta – United States double tax agreement (Treaty). 

The CAA states that, under the original intent of the Treaty, U.S. citizens and residents are not entitled to Treaty benefits with respect to personal retirement schemes established in Malta under the Retirement Pensions Act of 2011 because these schemes are not operated principally to administer or provide pension or retirement benefits. The CAA also makes clear that Treaty benefits are not available to any other fund, scheme, or arrangement (except for qualified rollovers) that (1) can accept contributions from a participant in a form other than cash or (2) does not limit contributions by reference to earned income from personal services of the participant or the participant’s spouse.