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June 26, 2026

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

Contents

Article 1 - Persons Covered

Article 2 - Taxes Covered

Article 3 - General Definitions

Article 4 - Resident

Article 5 - Permanent Establishment

Article 6 - Income from Immovable Property

Article 7 - Business Profits

Article 8 - Shipping and Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Interest

Article 12 - Royalties

Article 13 - Capital Gains

Article 14 - Independent Personal Services

Article 15 - Dependent Personal Services

Article 16 - Directors' Fees and Remuneration of Top-Level Managerial Officials

Article 17 - Artistes and Sportspersons

Article 18 - Pensions and Social Security Payments

Article 19 - Government Service

Article 20 - Teachers and Researchers

Article 21 - Students

Article 22 - Other Income

Article 23 - Elimination of Double Taxation

Article 24 - Non-Discrimination

Article 25 - Mutual Agreement Procedure

Article 26 - Exchange of Information

Article 27 - Miscellaneous Rules

Article 28 - Members of Diplomatic Missions and Consular Posts

Article 29 - Entry into Force

Article 30 - Termination

Article 1
Persons Covered

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

Article 2
Taxes Covered