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This Protocol amends the 1999 DTAA, updating its title to include the prevention of tax evasion and avoidance. Key changes include revised dividend withholding tax rates, with tax so charged not to exceed 15% and a 0% exemption for companies holding at least 10% of capital (Article 6). It establishes a new maximum interest withholding tax rate of 10%, with exemptions for specific loans (Article 7). The Protocol also adds new rules for taxing capital gains on shares deriving value from immovable property (Article 8) and introduces a comprehensive Exchange of Information article (Article 13).

Protocol between the SWISS CONFEDERATION and the STATE OF KUWAIT Amending the Agreement of 16 February 1999 between the SWISS CONFEDERATION and the STATE OF KUWAIT for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital

The Swiss Federal Council and The Government of the State of Kuwait

DESIRING to conclude a Protocol amending the Agreement of 16 February 1999 between the Swiss Confederation and the State of Kuwait for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital (hereinafter referred to as "the Agreement"),

HAVE AGREED as follows:

Contents

Article 1 - Title and Preamble Amendment

Article 2 - Taxes Covered

Article 3 - General Definitions

Article 4 - Resident

Article 5 - Associated Enterprises

Article 6 - Dividends

Article 7 - Interest

Article 8 - Capital Gains

Article 9 - Pensions and Annuities

Article 10 - Elimination of Double Taxation

Article 11 - Non-discrimination

Article 12 - Mutual Agreement Procedure

Article 13 - Exchange of Information and Entitlement to Benefits

Article 14 - Protocol Amendments

Article 15 - Entry into Force

Article 1
Title and Preamble Amendment

The title of the Agreement shall be deleted and replaced by the following title: "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 and the prevention of tax evasion and avoidance"
The preamble of the Agreement shall be deleted and replaced by the following preamble: "The Swiss Federal Council and The Government of the State of Kuwait DESIRING to further develop their economic relationship and to enhance their cooperation in tax matters, INTENDING to conclude an Agreement for the elimination of double taxation with respect to taxes on income and on capital without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Agreement for the indirect benefit of residents of third States), Have agreed as follows:"

Article 2
Taxes Covered

Subparagraph a) of paragraph 3 of Article 2 (Taxes Covered) of the Agreement shall be deleted and replaced by the following subparagraph:

Article 1Title and Preamble Amendment

Article 2Taxes Covered

Article 1
Title and Preamble Amendment

Article 2
Taxes Covered