DT11454 - Double Taxation Relief Manual: Kuwait: interest
Interest arising in Kuwait and paid to a resident of the UK who is the beneficial ownerof the interest is exempt from tax in Kuwait (Article 11(1)), except where the interest is effectively connected with a permanent establishment or fixed base which the UK resident recipient has in Kuwait. In the latter circumstances, the provisions of the Business profits Article (Article 7) or the Independent personal services Article (Article 14) will apply.