Approval by Ireland of the tax treaty between Ireland and Kuwait

Signed at Kuwait City on the 23rd of November 2010, the tax treaty between Ireland and Kuwait was ratified by Ireland, according to SI No 21/2011.

The main rules governing the permanent establishment in this treaty are as follows:

According to the tax treaty, the term ‘permanent establishment' means a fixed place of business through which the business of an enterprise is wholly or partly carried on.

A building site, a construction, assembly, erection 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 9 months