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This document is a Protocol, signed March 25, 2021, amending the 2007 Convention between Kuwait and Luxembourg. It updates the Preamble to reflect the intention to prevent treaty-shopping. It also replaces several key articles: Article 2 (Taxes Covered) is updated, Article 25 (Mutual Agreement Procedure) is modified, and Article 26 (Exchange of Information) is replaced with a more comprehensive version. Crucially, it introduces a new Article 29, "Entitlement to Benefits", a principal purpose test designed to combat treaty abuse and ensure benefits are not granted inappropriately.

PROTOCOL amending the Convention between the Government of the Grand Duchy of LUXEMBOURG and the Government of the State of KUWAIT for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, signed at Luxembourg on 11^th December 2007

The Government of the Grand Duchy of Luxembourg and the Government of the State of Kuwait

Desiring to conclude a Protocol amending the Convention between the Government of the Grand Duchy of Luxembourg and the Government of the State of Kuwait for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, signed at Luxembourg on 11^th December 2007, (hereinafter referred to as "the Convention"), have agreed as follows:

Contents

Article 1 - Amendment to the Preamble

Article 2 - Amendment to Taxes Covered

Article 3 - Amendment to Mutual Agreement Procedure

Article 4 - Amendment to Exchange of Information

Article 5 - Amendment to Entitlement to Benefits

Article 6 - Entry into Force

Article 1
Amendment to the Preamble

The preamble of the Convention shall be deleted and replaced by the following:

"The Government of the Grand Duchy of Luxembourg and the Government of the State of Kuwait

Desiring to further develop their economic relationship and to enhance their co-operation in tax matters,

Intending to conclude a Convention 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 Convention for the indirect benefit of residents of third States), have agreed as follows:"

Article 2
Amendment to Taxes Covered

Paragraph 3 of Article 2 (Taxes Covered) of the Convention shall be deleted and replaced by the following:

"3. The existing taxes to which this Convention shall apply are in particular:

Article 1Amendment to the Preamble

Article 2Amendment to Taxes Covered

Article 1
Amendment to the Preamble

Article 2
Amendment to Taxes Covered