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HMRC internal manual

Double Taxation Relief Manual

Kuwait: Royalties

Royalties arising in Kuwait and paid to a resident of the UK who is the beneficialowner 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 orfixed base which the UK resident recipient has in Kuwait, the provisions of the BusinessProfits Article (Article 7) or the Independent personal services Article (Article 14) willapply.