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1. This Agreement shall apply to taxes on income and on capi- tal imposed on behalf of a Contracting State, of a Land or a politi- cal subdivision or local authority thereof, irrespective of the manner in which they are levied.
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2. There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on el- ements of income or of capital, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation.
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3. The existing taxes to which the Agreement shall apply are in particular: (a) in the Federal Republic of Germany: the Einkommensteuer (income tax), the Koerperschaftsteuer (corporation tax), the Vermoegensteuer (capital tax), and the Gewerbesteuer (trade tax), (hereinafter referred to as “German tax”); (b) in the State of Kuwait: the corporate income tax, the 5 % of the net profits of shareholding companies payable to the Kuwait Foundation of Advancement of Science (KFAS), the Zakat, (hereinafter referred to as “Kuwaiti tax”).
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4. The Agreement shall apply also to any identical or substan- tially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. At the end of each year, the competent authorities of the Con- tracting States shall – if necessary – notify each other of changes which have been made in their respective taxation laws.