Egypt ratifies its DTA with Kuwait

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Egypt ratifies its DTA with Kuwait

Sponsored by

Eurofast Egypt
AdobeStock_104910373_Egypt

The Egyptian President Abdel Fatah El Sisi issued Presidential Decree No. 155 of 2016 on February 23 2017, ratifying the double tax treaty concluded between Egypt and Kuwait on December 16 2014.

najm.jpg

Ali Najm

The convention between Egypt and Kuwait serves the purpose of avoiding double taxation in connection with the taxes applied on income in both countries and to mitigate the risk of tax evasion by both countries' taxpayers. This convention will be in force for five years and will continue to be valid for the same term/s unless one of the countries notifies the other with its termination notice six months before the termination date. Once effective, it will replace the previous tax treaty signed between the two countries in 2004.

All taxes applied to income, including the taxes on profits resulting from transferrable or non-transferrable belongings, real estate and the taxes applied to the salaries and wages paid by the projects, is subject to the convention. The provisions of the agreement are also applied to any similar taxes in its nature, which may be introduced after the date of signing the treaty.

The tax treaty states that profits achieved by a project of any of the two countries are subject to taxes in its country of origin only, unless the project is performing activities in the other country through a permanent establishment there. In such a case, the profits achieved by the permanent establishment shall be subject to taxes in that other country. Each country shall then determine its share of the profits.

As for international transport activities, the profits resulting from operating vessels or airplanes are subject to taxes only in the country in which the physical headquarters of the project is located. However, if the physical headquarters of a maritime project is a vessel, it is considered located inside the country of the vessel's port even if the port is not located in the country in which the vessel's operator is residing.

In regards to interest, the applied withholding tax shall not exceed 10% of the total interest paid. A lower 5% withholding tax rate will be applicable if the beneficial owner is a company owning at least 10% of the capital in the dividend-distributing entity. Interest and royalties are also subject to a 10% withholding tax rate.

The convention has also spotlighted the treatment of the income received by actors and sports players who are residing in one of the two countries and acting as cinema or theatre actors, radio or television presenters, musicians or sports players. The income from these activities can be subject to taxes in the country of residence unless the assignment/visit is totally or partially financed by public funds from his/her country.

Ali Najm (ali.najm@eurofast.eu)

Eurofast Global

Tel: +357 22699222

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

Uncertainty isn’t always a bad thing, but it’s easy to see how the Trump administration’s IRS commissioner merry-go-round may serve to undermine business confidence
The EU defended its ‘sovereign right’ to impose the tax in the face of US tariff threats; in other news, the US deputy Treasury secretary resigned after just five months
Ascoria’s chief revenue officer shares her career wisdom garnered from the disparate worlds of tax technology, electric cables, radio DJing and more
Businesses no longer have a choice when it comes to tax technology transformation. Pavlo Boyko of TMF Group says the question is simply: sink or swim?
The firm is hunting for a senior TP manager in its quest to build a full-service practice in Indonesia, A&M Tax’s Jakarta head Jaap Zwaan tells ITR
With a new government in place, the evolving tax landscape presents both opportunities and challenges for taxpayers
Major economies have expressed concerns, with China arguing a US global minimum tax exemption would be a violation of the principle of fair competition – ITR understands
Senator Richard Colbeck told ITR he was concerned by the decision to let PwC Australia tender for government contracts again after a scandal-induced ban
Whether it be due to a fragmented advisory market or a rise in M&A, Italy’s frenetic hiring has not gone unnoticed by ITR’s Talent Tracker
The deal gives Azets 14 new partners and boosts its Swedish revenues to over $100 million; in other news, Svalner Atlas launched in Copenhagen
Gift this article