DT11455 | Double Taxation Relief Manual: Kuwait: royalties

Royalties arising in Kuwait and paid to a resident of the UK who is the beneficial owner of the royalties may be taxed in Kuwait at a rate of 10 per cent (Article 12(2)).

Where, however, the royalties are effectively connected with a permanent establishment or fixed base which the UK resident recipient has in Kuwait, the provisions of the Business Profits Article (Article 7) or the Independent personal services Article (Article 14) will apply.