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June 26, 2026

Treaty between the Kingdom of Saudi Arabia and the State of Kuwait facilitates the avoidance of double taxation and the prevention of fiscal evasion regarding taxes on income. It explicitly covers the Saudi Zakat and Income Tax, alongside Kuwaiti Income Tax decrees. Key provisions address the definition of permanent establishment (Article 5), the taxation of business profits, and specific withholding tax rates on dividends, royalties, and technical services. The Agreement mandates the elimination of double taxation through deduction methods and establishes robust frameworks for mutual agreement procedures and the exchange of information to ensure strict tax compliance between the Contracting States.

Agreement between The Government of the KINGDOM OF SAUDI ARABIA and the Government of the STATE OF KUWAIT for the Avoidance of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance

The Government of the Kingdom of Saudi Arabia and the Government of the State of Kuwait,

wishing to further develop their economic relations and strengthen their cooperation in tax matters, and desiring to conclude an Agreement for the Avoidance of Double Taxation with respect to taxes on income without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through arrangements aimed at obtaining treaty benefits intended to be granted under this Agreement for the indirect benefit of residents of third States or jurisdictions),

have agreed as follows:

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, Air and Land Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Income from Debt-Claims

Article 12 - Royalties

Article 13 - Income from Technical Services

Article 14 - Capital Gains

Article 15 - Independent Personal Services

Article 16 - Dependent Personal Services

Article 17 - Directors' Fees

Article 18 - Artistes and Sportspersons

Article 19 - Pensions

Article 20 - Government Service

Article 21 - Teachers and Researchers

Article 22 - Students and Trainees

Article 23 - Government Investments

Article 24 - Other Income

Article 25 - Methods of Elimination of Double Taxation

Article 26 - Mutual Agreement Procedure

Article 27 - Exchange of Information

Article 28 - Members of Diplomatic Missions and Consular Posts

Article 29 - Entitlement to Benefits

Article 30 - Entry into Force

Article 31 - Termination

Article 1
Persons Covered

This Agreement shall apply to persons who are residents of one or both of the Contracting States.
For the purposes of this Agreement, income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either Contracting State shall be considered as income derived by a resident of a Contracting State but only to the extent that the income is treated for purposes of taxation by that Contracting State as the income of a resident of that State.

This is an unofficial / best effort translation

Article 1Persons Covered

Article 1
Persons Covered