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June 26, 2026

The Agreement between the State of Kuwait and the Republic of Armenia, signed on 03/11/2009, is established for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital. Under the Convention, Kuwait lodges reservations for Articles 3, 4, 8, 9, 10, 11, and 12, covering entities, residency, and anti-abuse rules. Kuwait has also notified its choice to apply Article 6(3) regarding treaty purpose and Option A under Article 13(1) for preventing artificial avoidance of permanent establishment status.

The State of KUWAIT

For jurisdictions providing a provisional list:

This document contains a provisional list of expected reservations and notifications to be made by the State of Kuwait pursuant to Articles 28(7) and 29(4) of the Convention.

Contents

Article 2 - Interpretation of Terms

Article 3 - Transparent Entities

Article 4 - Dual Resident Entities

Article 6 - Purpose of a Covered Tax Agreement

Article 7 - Prevention of Treaty Abuse

Article 8 - Dividend Transfer Transactions

Article 9 - Capital Gains from Alienation of Shares or Interests of Entities Deriving their Value Principally from Immovable Property

Article 10 - Anti-abuse Rule for Permanent Establishments Situated in Third Jurisdictions

Article 11 - Application of Tax Agreements to Restrict a Party's Right to Tax its Own Residents

Article 12 - Artificial Avoidance of Permanent Establishment Status through Commissionnaire Arrangements and Similar Strategies

Article 13 - Artificial Avoidance of Permanent Establishment Status through the Specific Activity Exemptions

Article 16 - Mutual Agreement Procedure

Article 17 - Corresponding Adjustments

Article 2
Interpretation of Terms

Notification - Agreements Covered by the Convention

Pursuant to Article 2(1)(a)(ii) of the Convention, the state of Kuwait wishes the following agreements to be covered by the Convention:

Article 2Interpretation of Terms

Article 2
Interpretation of Terms