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Document Type: Double Taxation Agreement
Countries: 🇦🇪 UAE - 🇰🇼 The State of KUWAIT
Country Code: KWT
Translation: Official

The State of KUWAIT

Kuwait - Country List for Avoidance of Double Taxation Agreements - DTAA

The State of KUWAIT

For jurisdictions providing a provisional list:

This document contains a provisional list of expected reservations and notifications to be made by the State of Kuwait pursuant to Articles 28(7) and 29(4) of the Convention.

Article 2
Interpretation of Terms

Notification - Agreements Covered by the Convention

Pursuant to Article 2(1)(a)(ii) of the Convention, the state of Kuwait wishes the following agreements to be covered by the Convention:

NoTitleOther Contracting
Jurisdiction
Original/ Amending
Instrument
Date of SignatureDate of Entry into
Force

1

Agreement Between the Government of the State of Kuwait and the Government of the Republic of Armenia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Armenia

Original

03/11/2009

12/04/2013

2

Agreement Between the Government of the State of Kuwait and the Government of the Kingdom of Belgium for the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital and for the Fostering of Economic Relations

Belgium

Original

10/3/1990

29/10/2000

3

Agreement Between Bosnia and Herzegovina and the State of Kuwait for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital

Bosnia and Herzegovina

Original

28/10/2008

N/A

4

Agreement Between the Government of the State of Kuwait and the Government of the Republic of Bulgaria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Bulgaria

Original

29/10/2002

23/2/2004

5

Agreement between the Government of Canada and the Government of the State of Kuwait for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital

Canada

Original

28/01/2002

26/08/2003

6

Agreement Between the Government of the State of Kuwait and the Government of the People's Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital

China

Original

25/12/1989

20/7/1990

7

Agreement Between the Government of the State of Kuwait and the Government of the Republic of Croatia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Croatia

Original

29/8/2001

9/1/2003

8

Convention Between the Government of the State of Kuwait and the Government of the Republic of Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Cyprus

Original

5/10/2010

25/10/2013

9

Agreement Between the Government of the State of Kuwait and the Government of the Czech Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Czech Republic

Original

5/6/2001

3/3/2004

10

Agreement Between the Government of the State of Kuwait and the Government of the Kingdom of Denmark for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Denmark

Original

22/6/2010

2/10/2013

11

ةيروهمج ةموكحو تيوكلا ةلود ةموكح نيب ةيقافتا عنمو يبيرضلا جاودزالا بنجتل ةيبرعلا رصم لخدلا ىلع بئارضلا نم برهتلا

Egypt

Original

16/12/2014

23/11/2016

12

Convention entre le Gouvernement de la République Française et le Gouvernement de l´État de Koweit en vue d´éviter les doubles impositions en matière d´impôts sur le revenu, sur la fortune et sur les successions (Ensemble un protocole)

France

Original

07/02/1982

01/09/1983

Amending Instrument (a)

27/09/1989

01/07/1991

Amending Instrument (b)

27/01/1994

01/03/1995

13

Agreement Between the Government of the State of Kuwait and the Government of the Hellenic Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Greece

Original

2/3/2003

20/4/2005

14

Agreement Between the Government of the State of Kuwait and the Government of the Hong Kong Special Administrative Region of the People's Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Hong Kong

Original

13/5/2010

24/7/2013

15

Agreement Between the Government of the State of Kuwait and the Government of the Republic of India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

India

Original

15/6/2006

17/10/2007

Amending Instrument (a)

15/1/2017

N/A

16

Agreement Between the Government of the State of Kuwait and the Government of the Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Ireland

Original

23/11/2010

12/8/2013

17

Convention Between the Government of the State of Kuwait and Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Japan

Original

17/2/2010

14/6/2013

18

Agreement Between the Government of the State of Kuwait and the Government of the Republic of Kenya for the Avoidance of Double Taxation of Fiscal Evasion with respect to Taxes on Income and Capital

Kenya

Original

12/11/2013

N/A

19

Convention Between the Republic of Korea and the State of Kuwait for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital

Korea (South)

Original

05/12/1998

13/06/2000

Amending Instrument (a)

02/10/2007

27/12/2010

20

Agreement Between the Government of the State of Kuwait and the Government of the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Lithuania

Original

18/04/2013

N/A

21

Agreement Between the Government of the State of Kuwait and the Government of Malaysia for the Prevention of Fiscal Evasion with respect to Taxes on Income and for the Fostering of Economic Relations

Malaysia

Original

5/2/2003

29/5/2007

Amending Instrument (a)

5/1/2010

N/A

22

Agreement Between the Government of the State of Kuwait and the Government of Malta for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Malta

Original

24/7/2002

18/3/2004

23

Agreement Between the Government of the Republic of Mauritius and the Government of the State of Kuwait for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains

Mauritius

Original

24/03/1997

01/09/1998

24

Convention Between the Government of the State of Kuwait and the Government of the United of Mexican State for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Mexico

Original

27/10/2009

18/6/2013

25

ةكلمملا ةموكحو تيوكلا ةلود ةموكح نيب ةيقافتا اميف برهتلا عنمو يبيرضلا جاودزالا بنجتل ةيبرغملا لخدلا ىلع بئارضلاب قلعتي

Morocco

Original

15/06/2002

15/07/2006

26

Agreement Between the Government of the State of Kuwait and the Government of the Kingdom of the Netherlands for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Netherlands

Original

29/5/2001

23/4/2002

27

Agreement Between the Government of the State of Kuwait and the Government of the Islamic Republic of Pakistan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Pakistan

Original

30/6/1998

1/1/1999

28

Convention Between the State of Kuwait And the Portuguese Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Portugal

Original

23/2/2010

4/12/2013

29

Agreement Between the State of Kuwait and Romania for the Avoidance of Double Taxation with respect to Taxes on Income and Capital

Romania

Original

26/7/1992

1/1/1995

30

Agreement Between the Government of the State of Kuwait and the Russian Federation for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Russia

Original

9/2/1999

2/1/2003

31

Agreement Between the Government of the State of Kuwait and the Government Senegal for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Senegal

Original

9/4/2007

N/A

32

Agreement Between the Government of the State of Kuwait and the Government of the Federal Republic of Yugoslavia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Serbia

Original

2/4/2002

1/1/2004

33

Agreement Between the Government of the Republic of Seychelles and the Government of the State of Kuwait for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Seychelles

Original

05/02/2008

N/A

34

Agreement Between the Republic of Singapore and the State of Kuwait for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Singapore

Original

21/02/2002

02/07/2003

35

Agreement Between the Government of the State of Kuwait and the Government of the Slovak Republic for the Prevention of Fiscal Evasion with respect to Taxes on Income

Slovak Republic

Original

5/2/2002

23/2/2004

36

Convention Between the Government of the State of Kuwait and the Government of the Republic of Slovenia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Slovenia

Original

11/1/2010

17/5/2013

37

Agreement Between the Government of the State of Kuwait and the Government of the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

South Africa

Original

17/2/2004

25/4/2006

38

Convention Between the Government of the State of Kuwait and the Kingdom of Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Spain

Original

26/5/2008

18/7/2013

39

Agreement Between the State of Kuwait and the Democratic Socialist Republic of Sri Lanka for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Sri Lanka

Original

05/02/2002

23/02/2004

40

Agreement Between the Swiss Confederation and the State of Kuwait for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital

Switzerland

Original

16/02/1999

31/05/2000

41

Agreement Between the Kingdom of Thailand and the State of Kuwait for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Thailand

Original

29/07/2003

25/04/2006

42

ةيسنوتلا ةيروهمجلاو تيوكلا ةلود نيب ةيقافتا اميف برهتلا عنمو يبيرضلا جاودزالا بنجتل لخدلا ىلع بئارضلاب قلعتي

Tunisia

Original

18/04/2000

20/03/2002

43

Agreement Between the State of Kuwait and the Republic of Turkey for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Turkey

Original

6/10/1997

13/12/1999

44

Agreement Between the United Kingdom of Great Britain and Northern Ireland and the State of Kuwait for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

United Kingdom

Original

23/02/1999

01/07/2000

45

Agreement between the Government of the Socialist Republic of Vietnam and the Government of the State of Kuwait for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

Vietnam

Original

10/03/2009

11/02/2011

Article 3
Transparent Entities

Reservation

Pursuant to Article 3(5)(a) of the Convention, the State of Kuwait reserves the right for the entirety of Article 3 not to apply to its Covered Tax Agreements.

Article 4
Dual Resident Entities

Reservation

Pursuant to Article 4(3)(a) of the Convention, the state of Kuwait reserves the right for the entirety of Article 4 not to apply to its Covered Tax Agreements.

Article 6
Purpose of a Covered Tax Agreement

Notification of Choice of Optional Provisions

Pursuant to Article 6(6) of the Convention, the State of Kuwait hereby chooses to apply Article 6(3).

Notification of Existing Preamble Language in Listed Agreements

Pursuant to Article 6(5) of the Convention, the State of Kuwait considers that the following agreements are not within the scope of a reservation under Article 6(4) and contains preamble language described in Article 6(2). The text of the relevant preamble paragraph is identified below.

Listed Agreement NumberOther Contracting JurisdictionPreamble Text

1

Armenia

desiring to conclude an Agreement for the avoidance of double taxation of fiscal evasion with respect to taxes on income and on capital,

2

Belgium

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital and for the fostering of economic relations.

3

Bosnia and Herzegovina

Desiring to promote their mutual relations through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital;

4

Bulgaria

Desiring to promote their mutual economic relations through the conclusion between them of a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

5

Canada

desiring to promote their mutual economic relations by removing fiscal obstacles, through the conclusion of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital;

6

China (People's Republic of)

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital.

7

Croatia

Desiring to promote their mutual economic relations by removing fiscal obstacles through the conclusion of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

8

Cyprus

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

9

Czech Republic

Desiring to promote their mutual economic relations through the conclusion of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

10

Denmark

Desiring to promote their mutual economic relations through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

11

Egypt

ةيقافتا ماربا لالخ نم ةلدابتملا ةيداصتقالا امهتاقالع زيزعت يف امهنم ةبغر .لخدلا ىلع ةضورفملا بئارضلا نم برهتلا عنمو يبيرضلا جاودزالا بنجتل

13

Greece

Desiring to promote their mutual economic relations through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

14

Hong Kong (China)

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

15

India

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and with a view to promoting economic cooperation between the two countries.

16

Ireland

Desiring to promote their mutual economic relations through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

17

Japan

Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

18

Kenya

desiring to promote their mutual economic relations through the conclusion between them of an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital;

20

Lithuania

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

21

Malaysia

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and for the fostering of economic relations.

22

Malta

Desiring to promote their mutual economic relations by removing fiscal obstacles through the conclusion of a convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

23

Mauritius

desiring to promote their mutual economic relations by removing fiscal obstacles through the conclusion of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital,

24

Mexico

Desiring to promote their mutual economic relations through the conclusion between them of a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

25

Morocco

بنجتل ةيقافتا ماربا لالخ نم ةيداصتقالا امهتقالع زيزعتو ةيمنت يف امهنم ةبغر ؛لخدلا ىلع بئارضلاب قلعتي اميف برهتلا عنمو يبيرضلا جاودزالا

26

Netherlands

Desiring to promote their mutual economic relations through the conclusion between the Kingdom of the Netherlands and the State of Kuwait of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

27

Pakistan

Desiring to promote their mutual economic relations by removing fiscal obstacles through the conclusion of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

28

Portugal

Desiring to promote their mutual economic relations through the conclusion between both Contracting States of a convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

30

Russia

Desiring to promote their mutual economic relations through the conclusion of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

31

Senegal

Desiring to promote their mutual economic relations through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

32

Serbia

Desiring to promote their mutual economic relations through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

33

Seychelles

Desiring to promote their mutual economic relations through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital;

34

Singapore

desiring to conclude an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,

35

Slovak Republic

Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income

36

Slovenia

Desiring to promote their mutual economic relations through the conclusion between them of a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

37

South Africa

Desiring to promote their mutual economic relations through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

38

Spain

Desiring to promote their mutual economic relations through the conclusion between them of a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital;

39

Sri Lanka

desiring to promote their mutual economic relations through the conclusion of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income;

40

Switzerland

Desiring to conclude an agreement to avoid double taxation with respect to taxes on income and on capital,

41

Thailand

desiring to promote their mutual economic relations by removing fiscal obstacles through the conclusion of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income;

42

Tunisia

بنجتل ةيقافتا ماربإ لالخ نم ةلدابتملا ةيداصتقالا امهتقالع زيزعت يف امهنم ةبغر ؛لخدلا ىلع بئارضلاب قلعتي اميف برهتلا عنمو يبيرضلا جاودزالا

43

Turkey

Desiring to conclude an Agreement for the avoidance of double taxation with respect to taxes on income and on capital,

44

United Kingdom

Desiring to promote their mutual economic relations by removing fiscal obstacles through the conclusion of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital;

45

Vietnam

Desiring to promote their mutual economic relations through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

Notification of Listed Agreements Not Containing Existing Preamble Language

Pursuant to Article 6(6) of the Convention, the State of Kuwait considers that the following agreements do not contain preamble language referring to a desire to develop an economic relationship or to enhance co-operation in tax matters.

Listed Agreement NumberOther Contracting Jurisdiction

1

Armenia

3

Bosnia Herzegovina

5

Canada

6

China (People's Republic of)

8

Cyprus

12

France

14

Hong Kong (China)

17

Japan

18

Kenya

19

Korea (South)

20

Lithuania

23

Mauritius

25

Morocco

29

Romania

33

Seychelles

34

Singapore

35

Slovak Republic

39

Sri Lanka

40

Switzerland

41

Thailand

42

Tunisia

43

Turkey

44

United Kingdom

45

Vietnam

Article 7
Prevention of Treaty Abuse

Statement of Acceptance of the PPT as an Interim Measure

Pursuant to Article 7(17)(a) of the Convention, the State of Kuwait hereby expresses a statement that while the State of Kuwait accepts the application of Article 7(1) alone as an interim measure, it intends where possible to adopt a limitation on benefits provision, in addition to or in replacement of Article 7(1), through bilateral negotiation.

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 7(17)(a) of the Convention, the State of Kuwait considers that the following agreements are not subject to a reservation described in Article 7(15)(b) and contain a provision described in Article 7(2). The article and paragraph number of each such provision is identified below.

Listed Agreement NumberOther Contracting JurisdictionProvision

4

Bulgaria

Article 12(7)

9

Czech Republic

Article 27(4)

15

India

Article 27

19

Korea (South)

Article 28A

44

United Kingdom

Articles 10(6),11(5),12(7),22(4),

P.(4)

Article 8
Dividend Transfer Transactions

Reservation

Pursuant to Article 8(3)(a) of the Convention, the State of Kuwait reserves the right for the entirety of Article 8 not to apply to its Covered Tax Agreements.

Article 9
Capital Gains from Alienation of Shares or Interests of Entities Deriving their Value Principally from Immovable Property

Reservation

Pursuant to Article 9(6)(a) of the Convention, the State of Kuwait reserves the right for Article 9(1) not to apply to its Covered Tax Agreements.

Article 10
Anti-abuse Rule for Permanent Establishments Situated in Third Jurisdictions

Reservation

Pursuant to Article 10(5)(a) of the Convention, the State of Kuwait reserves the right for the entirety of Article 10 not to apply to its Covered Tax Agreements.

Article 11
Application of Tax Agreements to Restrict a Party's Right to Tax its Own Residents

Reservation

Pursuant to Article 11(3)(a) of the Convention, the State of Kuwait reserves the right for the entirety of Article 11 not to apply to its Covered Tax Agreements.

Article 12
Artificial Avoidance of Permanent Establishment Status through Commissionnaire Arrangements and Similar Strategies

Reservation

Pursuant to Article 12(4) of the Convention, the State of Kuwait reserves the right for the entirety of Article 12 not to apply to its Covered Tax Agreements.

Article 13
Artificial Avoidance of Permanent Establishment Status through the Specific Activity Exemptions

Notification of Choice of Optional Provisions

Pursuant to Article 13(7) of the Convention, the State of Kuwait hereby chooses to apply Option A under Article 13(1).

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 13(7) of the Convention, the State of Kuwait considers that the following agreements contain a provision described in Article 13(5)(a). The article and paragraph number of each such provision is identified below.

Listed Agreement NumberOther Contracting JurisdictionProvision

1

Armenia

Article 5(4)

2

Belgium

Article 5 (4)

3

Bosnia and Herzegovina

Article 5(6)

4

Bulgaria

Article 5 (4)

5

Canada

Article 5(6)

6

China (People's Republic of)

Article 5 (4)

7

Croatia

Article 5 (7)

8

Cyprus

Article 5 (6)

9

Czech Republic

Article 5 (6)

10

Denmark

Article 5 (6)

11

Egypt

Article 5 (6)

12

France

Article 5A(4)

13

Greece

Article 5 (6)

14

Hong Kong (China)

Article 5 (4)

15

India

Article 5 (5)

16

Ireland

Article 5 (6)

17

Japan

Article 5 (4)

18

Kenya

Article 5(6)

19

Korea

Article 5(5)

20

Lithuania

Article 5(4)

21

Malaysia

Article 5 (3)

22

Malta

Article 5 (6)

23

Mauritius

Article 5(6)

24

Mexico

Article 5 (7)

25

Morocco

Article 5(4)

26

Netherlands

Article 5 (6)

27

Pakistan

Article 5 (6)

28

Portugal

Article 5 (6)

29

Romania

Article 5 (4)

30

Russia

Article 5 (6)

31

Senegal

Article 5 (7)

32

Serbia

Article 5 (5)

33

Seychelles

Article 5(5)

34

Singapore

Article 5(6)

35

Slovak Republic

Article 5 (4)

36

Slovenia

Article 5 (5)

37

South Africa

Article 5 (6)

38

Sri Lanka

Article 5 (6)

39

Spain

Article 5(6)

40

Switzerland

Article 5(4)

41

Thailand

Article 5(4)

42

Tunisia

Article 5(4)

43

Turkey

Article 5 (3)

44

United Kingdom

Article 5(5)

45

Vietnam

Article 5(6)

Article 16
Mutual Agreement Procedure

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 16(6)(a) of the Convention, the State of Kuwait considers that the following agreements contain a provision described in Article 16(4)(a)(i). The article and paragraph number of each such provision is identified below.

Listed Agreement NumberOther Contracting JurisdictionProvision

1

Armenia

Article 25(1), first sentence

2

Belgium

Article 25(1), first sentence

3

Bosnia and Herzegovina

Article 26(1), first sentence

4

Bulgaria

Article 26(1), first sentence

5

Canada

Article 25(1), first sentence

6

China (People's Republic of)

Article 26(1), first sentence

7

Croatia

Article 25(1), first sentence

8

Cyprus

Article 24(1), first sentence

9

Czech Republic

Article 25(1), first sentence

10

Denmark

Article 25(1), first sentence

11

Egypt

Article 25(1), first sentence

12

France

Article 20(1), first sentence

13

Greece

Article 26(1), first sentence

14

Hong Kong (China)

Article 23(1), first sentence

15

India

Article 25(1), first sentence

16

Ireland

Article 24(1), first sentence

17

Japan

Article 24(1), first sentence

18

Kenya

Article 25(1), first sentence

19

Korea (South)

Article 26(1), first sentence

20

Lithuania

Article 25(1), first sentence

21

Malaysia

Article 25(1), first sentence

22

Malta

Article 25(1), first sentence

23

Mauritius

Article 26(1), first sentence

24

Mexico

Article 25(1), first sentence

25

Morocco

Article 25(1), first sentence

26

Netherlands

Article 26(1), first sentence

27

Pakistan

Article 25(1), first sentence

28

Portugal

Article 25(1), first sentence

29

Romania

Article 26(1), first sentence

30

Russia

Article 26(1), first sentence

31

Senegal

Article 25(1), first sentence

32

Serbia

Article 25(1), first sentence

33

Seychelles

Article 25(1), first sentence

34

Singapore

Article 25(1), first sentence

35

Slovak Republic

Article 24(1), first sentence

36

Slovenia

Article 25(1), first sentence

37

South Africa

Article 25(1), first sentence

38

Spain

Article 25(1), first sentence

39

Sri Lanka

Article 25(1), first sentence

40

Switzerland

Article 25(1), first sentence

41

Thailand

Article 25(1), first sentence

42

Tunisia

Article 25(1), first sentence

43

Turkey

Article 27(1), first sentence

44

United Kingdom

Article 27(1)

45

Vietnam

Article 25(1), first sentence

Pursuant to Article 16(6)(b)(i) of the Convention, the State of Kuwait considers that the following agreements contain a provision that provides that a case referred to in the first sentence of Article 16(1) must be presented within a specific time period that is shorter than three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Covered Tax Agreement. The article and paragraph number of each such provision is identified below.

Listed Agreement NumberOther Contracting JurisdictionProvision

5

Canada

Article 25(1), second sentence

12

France

Article 20(1), second sentence

Pursuant to Article 16(6)(b)(ii) of the Convention, the State of Kuwait considers that the following agreements contain a provision that provides that a case referred to in the first sentence of Article 16(1) must be presented within a specific time period that is at least three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Covered Tax Agreement. The article and paragraph number of each such provision is identified below.

Listed Agreement NumberOther Contracting JurisdictionProvision

1

Armenia

Article 25(1), second sentence

2

Belgium

Article 25(1), second sentence

3

Bosnia and Herzegovina

Article 26(1), second sentence

4

Bulgaria

Article 26(1), second sentence

6

China (People's Republic of)

Article 26(1), second sentence

7

Croatia

Article 25(1), second sentence

8

Cyprus

Article 24(1), second sentence

9

Czech Republic

Article 25(1), second sentence

10

Denmark

Article 25(1), second sentence

11

Egypt

Article 25(1), second sentence

13

Greece

Article 26(1), second sentence

14

Hong Kong (China)

Article 23(1), second sentence

15

India

Article 25(1), second sentence

16

Ireland

Article 24(1), second sentence

17

Japan

Article 24(1), second sentence

18

Kenya

Article 25(1), second sentence

19

Korea (South)

Article 26(1), second sentence

20

Lithuania

Article 25(1), second sentence

21

Malaysia

Article 25(1), second sentence

22

Malta

Article 25(1), second sentence

23

Mauritius

Article 26(1), second sentence

24

Mexico

Article 25(1), second sentence

25

Morocco

Article 25(1), second sentence

26

Netherlands

Article 26(1), second sentence

27

Pakistan

Article 25(1), second sentence

28

Portugal

Article 25(1), second sentence

29

Romania

Article 26(1), second sentence

30

Russia

Article 26(1), second sentence

31

Senegal

Article 25(1), second sentence

32

Serbia

Article 25(1), second sentence

33

Seychelles

Article 25(1), second sentence

34

Singapore

Article 25(1), second sentence

35

Slovak Republic

Article 24(1), second sentence

36

Slovenia

Article 25(1), second sentence

37

South Africa

Article 25(1), second sentence

38

Spain

Article 25(1), second sentence

39

Sri Lanka

Article 25(1), second sentence

40

Switzerland

Article 25(1), second sentence

41

Thailand

Article 25(1), second sentence

42

Tunisia

Article 25(1), second sentence

45

Vietnam

Article 25(1), second sentence

Pursuant to Article 16(6)(c)(ii) of the Convention, the State of Kuwait considers that the following agreements do not contain a provision described in Article 16(4)(b)(ii).

Listed Agreement NumberOther Contracting Jurisdiction

2

Belgium

24

Mexico

40

Switzerland

43

Turkey

45

United Kingdom

Pursuant to Article 16(6)(d)(ii) of the Convention, the State of Kuwait considers that the following agreements do not contain a provision described in Article 16(4)(c)(ii).

Listed Agreement NumberOther Contracting Jurisdiction

2

Belgium

28

Portugal

33

Seychelles

44

United Kingdom

Article 17
Corresponding Adjustments

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 17(4) of the Convention, the State of Kuwait considers that the following agreements contain a provision described in Article 17(2). The article and paragraph number of each such provision is identified below.

Listed Agreement NumberOther Contracting JurisdictionProvision

1

Armenia

Article 9(2)

2

Belgium

Article 9(2)

3

Bosnia and Herzegovina

Article 9(2)

4

Bulgaria

Article 9(2)

5

Canada

Article 9(2)

6

China

Article 9(2)

7

Croatia

Article 9(2)

8

Cyprus

Article 9(2)

9

Czech Republic

Article 9(2)

10

Denmark

Article 9(2)

11

Egypt

Article 9(2)

13

Greece

Article 9(2)

14

Hong Kong

Article 9(2)

15

India

Article 9(2)

16

Ireland

Article 9(2)

17

Japan

Article 9(2)

18

Kenya

Article 9(2)

19

Lithuania

Article 9(2)

22

Malta

Article 9(2)

23

Mauritius

Article 9(2)

24

Mexico

Article 9(2)

25

Morocco

Article 9(2)

26

Netherlands

Article 9(2)

27

Pakistan

Article 9(2)

28

Portugal

Article 9(2)

29

Romania

Article 9(2)

30

Russia

Article 9(2)

31

Senegal

Article 9(2)

32

Serbia

Article 9(2)

33

Seychelles

Article 9(2)

34

Singapore

Article 9(2)

35

Slovak Republic

Article 9(2)

36

Slovenia

Article 9(2)

37

South Africa

Article 9(2)

38

Spain

Article 9(2)

39

Sri Lanka

Article 9(2)

41

Thailand

Article 9(2)

42

Tunisia

Article 9(2)

43

Turkey

Article 9(2)

44

United Kingdom

Article 9(2)

45

Vietnam

Article 9(2)

About This Tax Treaty

This Double Taxation Avoidance Agreement between UAE and The State of KUWAIT provides:

  • Elimination of double taxation on income and capital
  • Prevention of tax evasion and avoidance
  • Clear residence rules for tax purposes
  • Reduced withholding taxes on cross-border payments