Agreement between the Government of the STATE OF KUWAIT and the Government of the STATE OF QATAR for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Article 1
Persons Covered

1. This Agreement shall apply to persons who are residents of one or both of the Contracting States.

2. Notwithstanding the other provisions of this Agreement, a collective investment vehicle established in a Contracting State that receives income arising in the other Contracting State shall be treated, for the purposes of applying the Agreement to such income, as an individual who is a resident of the Contracting State in which it is established and as the beneficial owner of the income it receives.

   For the purposes of this paragraph, the term "collective investment vehicle" means any investment fund, arrangement, or other entity established in either of the Contracting States which the competent authorities of the Contracting States agree to regard as a collective investment vehicle for the purposes of this paragraph.

Article 2
Taxes Covered by the Agreement

1. This Agreement shall apply to all taxes on income and on capital imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.

2. There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of elements of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

3. The existing taxes to which this Agreement shall apply are in particular:

   1. In the case of the State of Kuwait, taxes imposed under:

      1. Decree of Income Tax No. 3 of 1955 as amended by Law No. 2 of 2008;

      2. Law No. 19 of 2000 regarding the support of National Manpower and encouraging it to work in non-governmental entities.

      3. Kuwait Income Tax Law in the Designated Area No. 23 of 1961.

      4. Decree-Law No. 157 of 2024 promulgating the Tax Law on Multinational Enterprise Groups.

      (Hereinafter referred to as "Kuwaiti Tax");

   2. In the case of the State of Qatar:

      1. Income Tax.

      2. Corporate Tax.

      (Hereinafter referred to as "Qatari Tax").

4. This Agreement shall also apply to any identical or substantially similar taxes that are imposed after the date of signature of this Agreement in addition to the existing taxes.

   The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their respective taxation laws.

Article 3
General Definitions

1. For the purposes of this Agreement, unless the context otherwise requires:

   1. The term "Kuwait" means the territory of the State of Kuwait and includes any area beyond the territorial sea which, in accordance with international law, has been or may be designated under the laws of Kuwait as an area in which Kuwait may exercise sovereign rights or jurisdiction.

   2. The term "Qatar" means the State of Qatar, and when used in a geographical sense, it means the lands, internal waters, and territorial waters of the State of Qatar, including the seabed and subsoil thereof, and the airspace superjacent thereto, the exclusive economic zone, and the continental shelf, over which the State of Qatar exercises sovereign rights and jurisdiction in accordance with the provisions of international law and its internal laws and regulations;

   3. The term "person" includes an individual, a company, and any other body of persons;

   4. The term "company" means any body corporate or any entity that is treated as a body corporate for tax purposes;

   5. The term "enterprise" applies to the carrying on of any business;

   6. The terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;

   7. The term "international traffic" means any transport by a ship or aircraft operated by an enterprise that has its place of effective management in a Contracting State, except when the ship or aircraft is operated solely between places situated in the other Contracting State;

   8. The term "national", in relation to a Contracting State, means:

      1. Any individual possessing the nationality or citizenship of that Contracting State;

      2. Any legal person, partnership, or association deriving its status as such from the laws in force in that Contracting State.

   9. The term "business" includes the performance of professional services and of other activities of an independent character;

   10. The term "tax" means Kuwaiti tax or Qatari tax, as the context requires;

   11. The term "competent authority" means:

       1. In the case of Kuwait, the Minister of Finance or the Minister's authorized representative;

       2. In the case of Qatar, the Minister of Finance or his authorized representative.

   12. The term "recognized pension fund" of a Contracting State means an entity or arrangement established in that State that is treated as a separate person under the taxation laws of that State:

       1. That is established and operated exclusively or almost exclusively to administer or provide retirement benefits and ancillary or incidental benefits to individuals and is regulated as such by that State or one of its administrative or political subdivisions or local authorities;

       2. Or that is established and operated exclusively or almost exclusively to invest funds for the benefit of entities or arrangements referred to in subparagraph (1).

2. As regards the application of the Agreement at any time by a Contracting State, any term or expression not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that Contracting State for the purposes of the taxes to which this Agreement applies, and any meaning under the applicable tax laws of that State shall prevail over any meaning given to the term or expression under other laws of that State.

Article 4
Resident

1. For the purposes of this Agreement, the term "resident of a Contracting State" means:

   1. In the case of Kuwait: an individual who has his domicile in Kuwait and is a Kuwaiti national, and any company or entity incorporated in Kuwait.

   2. In the case of Qatar: any person who, under the laws of Qatar, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management, or any other criterion of a similar nature.

      However, this term does not include any person who is liable to tax in Qatar in respect only of income from sources in Qatar.

2. For the purposes of paragraph (1), the term "resident of a Contracting State" also includes:

   1. The Government of that Contracting State or any political subdivision or local authority thereof;

   2. any governmental institution established in that Contracting State under public law, such as a company or central bank, or a fund or recognized pension fund, or an authority, charitable institution, agency, or any other similar entity;

   3. Any entity established in that State or political subdivision or local authority thereof or an institution as defined in subparagraph (b), jointly with similar bodies from third states;

   4. A recognized pension fund in the Contracting State.

3. Where by reason of the provisions of paragraph (1) an individual is a resident of both Contracting States, then his status shall be determined as follows:

   1. He shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests);

   2. If the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode;

   3. If he has an habitual abode in both States, or if he has not an habitual abode in either of them, he shall be deemed to be a resident only of the State of which he is a national;

   4. If his status cannot be determined under the provisions of subparagraphs (a) through (c), the competent authorities of the Contracting States shall settle the question by mutual agreement.

4. Where by reason of the provisions of paragraph (1) of this Article a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which such person shall be deemed to be a resident for the purposes of this Agreement, having regard to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors.

   In the absence of such agreement, such person shall not be entitled to any relief or exemption from tax provided by this Agreement except to the extent and in such manner as may be agreed upon by the competent authorities of the Contracting States.

Article 5
Permanent Establishment

1. For the purposes of this Agreement, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on.

2. The term "permanent establishment" includes especially:

   1. A place of management;

   2. A branch;

   3. An office;

   4. A factory;

   5. A workshop;

   6. A farm or any cultivated land;

   7. A mine, an oil or gas well, a quarry, or any other place connected with the exploration or exploitation of natural resources.

3. An enterprise of a Contracting State, regarding activities for the exploration of natural resources in a place or area in the other Contracting State, shall be deemed to carry on such activities through a permanent establishment in that other State if such activities continue for a period longer than (12) twelve months.

4. The term "permanent establishment" also includes:

   1. A building site, a construction, assembly or installation project or supervisory activities in connection therewith carried out in a Contracting State, constitutes a permanent establishment only if such site, project or activities continue for a period of more than (12) twelve months.

   2. The furnishing of services, including consultancy or managerial services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose in the Contracting State shall constitute a permanent establishment only if such activities continue for a period or periods aggregating more than (183) days within any twelve-month period commencing or ending in the fiscal year concerned.

5. Subject to the provisions of paragraph (3), an enterprise of a Contracting State shall be deemed to have a permanent establishment in the other Contracting State if substantial equipment is used for a period exceeding 6 months within any twelve-month period commencing or ending in the fiscal year concerned in that Contracting State by, for, or under contract with the enterprise.

6. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include:

   1. The use of facilities solely for the purpose of storage, display, or delivery of goods or merchandise belonging to the enterprise;

   2. The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display, or delivery;

   3. The maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise;

   4. The maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information for the enterprise;

   5. The maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity;

   6. The maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character.

7. Notwithstanding the provisions of paragraphs (1) and (2) of this Article, where a person — other than an agent of an independent status to whom paragraph (8) applies — is acting on behalf of an enterprise of a Contracting State, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, if such a person has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph (6) which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph.

8. Paragraph (7) of this Article shall not apply where the person acting in a Contracting State on behalf of an enterprise of the other Contracting State carries on business in the first-mentioned State as an independent agent and acts in the ordinary course of that business.

   However, when the activities of such an agent are devoted wholly or almost wholly on behalf of one or more enterprises to which it is closely related, that person shall not be considered an independent agent within the meaning of this paragraph with respect to any such enterprise.

9. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.

10. For the purposes of this Article, a person or enterprise is closely related to an enterprise if, based on all relevant facts and circumstances, one has control over the other or both are under the control of the same persons or enterprises.

    In any case, a person or enterprise shall be considered closely related to an enterprise if one possesses directly or indirectly more than (50) per cent of the beneficial interest in the other (or, in the case of a company, more than (50) per cent of the aggregate vote and value of the company's shares or of the beneficial equity interest in the company) or if another person or enterprise possesses directly or indirectly more than (50) per cent of the beneficial interest (or, in the case of a company, more than (50) per cent of the aggregate vote and value of the company's shares or of the beneficial equity interest in the company) in the person and the enterprise or in the two enterprises.

Article 6
Income from Immovable Property

1. Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State.

2. Notwithstanding paragraph (1), income derived by an individual who is a national of a Contracting State from immovable property situated in the other Contracting State shall be taxable only in the State of which he is a national. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources. Ships and aircraft shall not be regarded as immovable property.

4. The provisions of paragraphs (1) and (2) shall apply to income derived from the direct use, letting, or use in any other form of immovable property.

5. The provisions of paragraphs (1) and (3) shall also apply to the income from immovable property of an enterprise.

Article 7
Business Profits

1. The profits of an enterprise of a Contracting State shall be taxable only in that Contracting State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on or is carrying on business as aforesaid, the profits of the enterprise may be taxed in that other Contracting State but only so much of them as is attributable to that permanent establishment.

2. Subject to the provisions of paragraph (3), where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.

3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere, taking into account any applicable laws or regulations.

4. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph (2) shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.

5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.

6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.

7. Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

Article 8
Shipping and Air Transport

1. Profits from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State in which the place of effective management of the enterprise is situated.

2. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include, but are not limited to:

   1. Profits from the rental of ships and aircraft on a bareboat basis;

   2. Profits from the use, maintenance, or rental of containers as well as trailers and related equipment for the transport of containers used for the transport of goods or merchandise.

   where such use, maintenance, or leasing, as the case may be, is incidental to the operation of ships or aircraft in international traffic.

3. The provisions of paragraph (1) shall apply to profits from the participation in a pool, a joint business, or an international operating agency.

Article 9
Associated Enterprises

1. Where:

   1. An enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or

   2. The same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,

   and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

2. Where a Contracting State includes in the profits of an enterprise of that Contracting State - and taxes accordingly - profits on which an enterprise of the other Contracting State has been charged to tax in that other Contracting State and the profits so included are profits which would have accrued to the enterprise in the first-mentioned Contracting State if the conditions made between the two enterprises had been those which would have been made between two independent enterprises, then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions of this Agreement and the competent authorities of the Contracting States shall if necessary consult each other.

3. A Contracting State shall not include in the profits of an enterprise, and tax accordingly, profits that would have accrued to that enterprise, but by reason of the conditions referred to in paragraph (1) have not so accrued, after 5 years from the end of the taxable year in which the profits would have accrued to the enterprise.

   The provisions of this paragraph shall not apply in the case of fraud, gross negligence, or willful default.

Article 10
Dividends

1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State shall be taxable only in that other State.

2. The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as income which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident.

3. The provisions of paragraph (1) of this Article shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply.

Article 11
Interest

1. Interest arising in a Contracting State and paid to a resident of the other Contracting State who is the beneficial owner of such interest shall be taxable only in that other Contracting State.

2. The term "interest" as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds, or debentures, as well as income which is subjected to the same taxation treatment as income from money lent under the taxation law of the Contracting State in which the income arises. The term also includes income from arrangements such as Islamic financial instruments where the substance of the underlying contract is akin to a loan. Penalty charges for late payment shall not be regarded as interest for the purposes of this Article.

3. The provisions of paragraph (1) of this Article shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises through a permanent establishment situated in the other Contracting State, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply.

4. Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the State in which the permanent establishment is situated.

5. Where, by reason of a special relationship between the payer and the beneficial owner of the interest or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner of the interest in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Article 12
Royalties

1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State.

2. However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 8% of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation.

3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic, or scientific work including cinematograph films, or films, tapes, or any other means of reproduction used in connection with television or radio broadcasting, or any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial, or scientific experience (know-how).

4. The provisions of paragraphs (1) and (2) shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply.

5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Article 13
Fees for Technical Services

1. Fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

2. However, subject to the provisions of Articles 8, 16, and 17 of this Agreement, fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the fees is a resident of the other Contracting State, the tax so charged shall not exceed 8% of the gross amount of the fees.

3. The term "fees for technical services" as used in this Article means any payments in consideration for any service of a managerial, technical or consultancy nature, unless the payment is made:

   1. to an employee of the person making the payment; or

   2. for teaching in an educational institution or for teaching by an educational institution; or

   3. By an individual for services for the personal use of the individual.

4. The provisions of paragraphs (1) and (2) shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise through a permanent establishment situated in that other State, and the fees for technical services are effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply.

5. For the purposes of this Article, subject to the provisions of paragraph (6), fees for technical services shall be deemed to arise in a Contracting State if the payer is a resident of that State or if the person paying the fees, whether that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the liability to pay the fees was incurred, and such fees are borne by such permanent establishment.

6. For the purposes of this Article, fees for technical services shall be deemed not to arise in a Contracting State if the payer is a resident of that State and carries on business in the other Contracting State through a permanent establishment situated therein and such fees are borne by that permanent establishment.

7. Where, by reason of a special relationship between the payer of the fees and the beneficial owner thereof or between both of them and some other person, the amount of the fees for technical services, having regard to the services for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount.

   In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Article 14
Capital Gains

1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State.

2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise), may be taxed in that other State.

3. Gains from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

4. Gains from the alienation of any property other than that referred to in paragraphs (1), (2), and (3) shall be taxable only in the Contracting State of which the alienator is a resident.

Article 15
Income from Employment

1. Subject to the provisions of Articles 16, 18, and 19, salaries, wages, and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.

2. Notwithstanding the provisions of paragraph (1), remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if all the following conditions are met:

   1. The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal year concerned;

   2. The remuneration is paid by, or on behalf of, an employer who is not a resident of the other State;

   3. The remuneration is not borne by a permanent establishment which the employer has in that State.

3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

4. Remuneration derived from employment exercised in connection with a ship or aircraft operated in international traffic, including employment exercised by the crew of the ship or aircraft and ground staff, shall be taxable only in the Contracting State of which the operator of such ship or aircraft is a resident.

Article 16
Directors' Fees

Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or a similar body of a company which is a resident of the other Contracting State shall be taxable only in the first-mentioned Contracting State.

Article 17
Artistes and Sportspersons

1. Notwithstanding the provisions of Article 15 of this Agreement, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.

2. Where income in respect of personal activities exercised by an entertainer or a sportsperson in his capacity as such accrues not to the entertainer or sportsperson himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.

3. The provisions of paragraphs (1) and (2) shall not apply to income derived by an entertainer or a sportsperson who is a resident of a Contracting State from his activities in the other Contracting State if the visit to that other State is supported wholly or mainly by public funds of the first-mentioned State, including any political subdivision, local authority, or statutory body thereof, or takes place under a cultural agreement or arrangement between the Governments of the Contracting States.

   The provisions of paragraphs (1) and (2) shall also not apply to income derived by non-profit organizations from such activities, provided that no part of their income is payable or available for the personal benefit of their proprietors, founders, or members.

Article 18
Pensions

Subject to the provisions of paragraph (2) of Article 19 of this Agreement, pensions and other similar remuneration paid to an individual who is a resident of a Contracting State in consideration of past employment shall be taxable only in that State.

Article 19
Government Service

1. 1. Salaries, wages, and other similar remuneration paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.

   2. However, such salaries, wages, and similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who:

      1. is a national of that State; or

      2. did not become a resident of that Contracting State solely for the purpose of rendering the services.

2. 1. Notwithstanding the provisions of paragraph (1), pensions and other similar remuneration paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.

   2. However, such pension and other similar remuneration shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.

3. The provisions of Articles 15, 16, 17, and 18 shall apply to salaries, wages, and other similar remuneration, and to pensions, in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.

Article 20
Teachers and Researchers

An individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State, and who, at the invitation of the Government of the first-mentioned Contracting State or of a university, college, school, museum or other cultural institution in that first-mentioned State or under an official programme of cultural exchange, is present in that State for a period not exceeding five consecutive years solely for the purpose of teaching, giving lectures or carrying on research at such institutions shall be exempt from tax in that State on the remuneration for such activity.

Article 21
Students and Trainees

1. Payments which a student or business apprentice receives for the purpose of his maintenance, education or training and who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his maintenance, education or training shall not be taxed in that State.

2. Notwithstanding the provisions of paragraph (1), remuneration for services rendered by a student or business apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training derived from temporary services in the first-mentioned State shall not be taxed in that State, provided that such services are in connection with his education or training and that the remuneration for such services is necessary to supplement the resources available for his maintenance.

Article 22
Other Income

1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that State.

2. The provisions of paragraph (1) shall not apply to income, other than income from immovable property as defined in paragraph (3) of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 of this Agreement shall apply.

Article 23
Capital

1. Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that State.

2. Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State may be taxed in that other State.

3. The provisions of the preceding paragraphs (1) and (2) shall not apply to capital owned by an individual who is a national of one of the Contracting States.

4. Capital represented by ships or aircraft operated in international traffic and by movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

5. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

Article 24
Government Investments

1. Notwithstanding any provision of this Agreement, investments of a Contracting State in the other Contracting State and income derived from such investments, including income mentioned in Articles 10, 11, and 14 of this Agreement, as well as gains from the alienation thereof, shall be taxable only in the first-mentioned Contracting State.

   However, the provisions of this Article shall not apply to income from immovable property or gains from the alienation thereof.

   The competent authorities of the Contracting States shall settle the mode of application of this provision by mutual agreement.

2. For the purposes of this Article and with respect to Kuwait, "investments of a Contracting State" referred to in paragraph (1) of this Article means investments made by:

   1. That State, or any administrative or political subdivision, local authority, statutory body, agency, instrumentality, or public law entity thereof, including:

      1. Central Bank of Kuwait;

      2. Kuwait Investment Authority;

      3. The Public Institution for Social Security;

      4. Kuwait Petroleum Corporation and its subsidiaries and affiliates;

      5. Kuwait Fund for Arab Economic Development;

      6. Kuwait Airways Corporation.

   2. Any entity wholly owned, directly or indirectly, by persons mentioned in subparagraph (a) of paragraph (2) of this Article.

   3. Any other similar entity that may be determined and agreed upon between the competent authorities of the Contracting States through an exchange of notes.

3. For the purposes of this Article and with respect to Qatar, "investments of a Contracting State" referred to in paragraph (1) of this Article means investments made by:

   1. That State, or any administrative or political subdivision, local authority, statutory body, agency, instrumentality, or public law entity thereof, including:

      1. Qatar Central Bank;

      2. Qatar Investment Authority;

      3. Qatar Airways;

      4. Qatar Energy and its subsidiaries;

      5. Qatar Petroleum International Ltd;

      6. Qatar Retirement and Pension Fund;

      7. Qatar Holding;

      8. Qatari Diar Real Estate Investment Company;

      9. Qatar Ports Management Company "Mwani Qatar".

   2. Any entity wholly owned, directly or indirectly, by persons mentioned in subparagraph (a) of paragraph (3) of this Article.

   3. Any other similar entity that may be determined and agreed upon between the competent authorities of the Contracting States through an exchange of notes.

Article 25
Elimination of Double Taxation

1. Where a resident of a Contracting State derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the other Contracting State, the first-mentioned State shall allow:

   1. A deduction from the tax on the income of that resident of an amount equal to the amount of the income tax paid in that other State;

   2. A deduction from the tax on the capital of that resident of an amount equal to the capital tax paid in that other State.

   Such deduction in either case shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in that other State.

2. For the purposes of allowing a deduction in a Contracting State, the tax paid in the other Contracting State shall be deemed to include the tax which is otherwise payable in that other Contracting State but has been exempted or reduced in accordance with special incentive laws and regulations designed to promote economic development in that other Contracting State.

Article 26
Non-Discrimination

1. Individuals who are nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith which is different from, or more burdensome than, the taxation and connected requirements to which nationals of that other Contracting State in the same circumstances are or may be subjected.

2. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favorably levied in that other State than the taxation levied on enterprises of that other Contracting State carrying on the same activities in the same circumstances.

   This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs, and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

3. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned Contracting State to any taxation or any requirement connected therewith which is different from, or more burdensome than, the taxation and connected requirements to which other similar enterprises, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, are or may be subjected.

4. Nothing in this Article shall be construed as imposing a legal obligation on a Contracting State to extend to the residents of the other Contracting State the benefit of any treatment, preference, or privilege which may be granted to any third state or its residents by virtue of the formation of a customs union, an economic union, a free trade area, or any regional or sub-regional arrangement relating wholly or mainly with taxes or the movement of capital to which the first-mentioned Contracting State may be a party.

5. Except where the provisions of paragraph (1) of Article 9, paragraph (5) of Article 11, paragraph (5) of Article 12, or paragraph (7) of Article 13 apply, interest, royalties, fees for technical services, and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State.

   Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State.

6. The term "taxation" in this Article means taxes which are the subject of this Agreement.

Article 27
Mutual Agreement Procedure

1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

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.

3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement.

4. The competent authorities of the Contracting States may communicate with each other directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs.

Article 28
Exchange of Information

1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Agreement.

   The exchange of information is not restricted by Articles 1 and 2.

2. Any information received by a Contracting State in accordance with paragraph (1) of this Article shall be treated as secret in the same manner as information obtained under the domestic laws of that State.

   They shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to the tax referred to in paragraph (1), or the oversight of the above. Such persons or authorities shall use this information only for such purposes.

   Notwithstanding the foregoing, information received by a Contracting State may be used for other purposes when such information may be used for such other purposes under the laws of both States and the competent authority of the supplying State authorizes such use.

3. In no case shall the provisions of the paragraphs be construed so as to impose on a Contracting State the obligation:

   1. To carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;

   2. To supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;

   3. To supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information the disclosure of which would be contrary to public policy (ordre public).

4. If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph (3) but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.

5. In no case shall the provisions of paragraph (3) be construed to permit a Contracting State to decline to supply information solely because the information is held by bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person.

Article 29
Miscellaneous Provisions

1. The provisions of this Agreement shall not be construed to restrict in any manner any privileges, exemptions, reductions, or other deductions now or hereafter granted by the laws of a Contracting State in the determination of the tax imposed by that State either:

   1. Under the laws of a Contracting State in the determination of the tax imposed by that State;

   2. Under any other agreement on taxation in the framework of economic and technical cooperation between the Contracting States or between one of the Contracting States and residents of the other Contracting State.

2. The competent authorities of each of the Contracting States shall be entitled to establish regulations for the implementation of the provisions of this Agreement.

Article 30
Entitlement to Benefits

Notwithstanding any provisions of this Agreement, a benefit under this Agreement shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Agreement.

Article 31
Members of Diplomatic Missions and Consular Posts

Nothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements.

Article 32
Entry into Force

1. Each of the Contracting States shall notify the other in writing through diplomatic channels of the completion of the legal procedures required for the entry into force of this Agreement.

2. This Agreement shall enter into force on the date of receipt of the latter of the two notifications and its provisions shall apply in both Contracting States as follows:

   1. In respect of taxes withheld at source, to amounts paid or credited on or after the first day of January of the calendar year next following the year in which this Agreement enters into force.

   2. In respect of other taxes, for tax years beginning on or after the first day of January of the calendar year next following the year in which this Agreement enters into force.

Article 33
Duration and Termination

This Agreement shall remain in force for a period of five years and shall continue in force thereafter for a similar period or periods unless either Contracting State notifies the other State in writing at least six months before the expiry of the initial period or any subsequent period of its intention to terminate this Agreement.

In such event, the Agreement shall cease to have effect in both Contracting States:

1. In respect of taxes withheld at source, to amounts paid or credited on or after the first day of January of the calendar year next following the year in which the notice of termination is given.

2. In respect of other taxes, for tax years beginning on or after the first day of January of the calendar year next following the year in which the notice of termination is given.

IN WITNESS WHEREOF the undersigned, being duly authorized thereto, have signed this Agreement.

Done at Kuwait City on this 5th day of Dhu al-Hijjah 1446 AH, corresponding to the 1st day of June 2025, in two originals in the Arabic language.

For the Government of the State of Kuwait: Eng. Noura Suleiman Salem Al-Fassam, Minister of Finance and Minister of State for Economic and Investment Affairs

For the Government of the State of Qatar: Ali bin Ahmed Al-Kuwari, Minister of Finance