Treaty between Kuwait and Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains

We have published in the newsletter of March 2011, the main rules relating to ‘permanent establishment' of the tax treaty between Kuwait and Ireland.

We highlighted the main rules relating to dividends, interests and royalties.

Dividends

Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State who is the beneficial owner of such dividends shall be taxable only in that other State.

Interests

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

Royalties