1. A person that is a resident of the State of Kuwait and derives
income from the Federal Republic of Germany shall be entitled
in the Federal Republic of Germany to all the benefits of the
Articles 8, 10 to 13 and paragraph 4 of Article 22 only if such
person is
(a) the State of Kuwait;
(b) a government institution of the State of Kuwait as defined in
sub-paragraph c) of paragraph 2 of Article 4;
(c) an individual;
(d) a company provided that such company – except the Gulf
Investment Corporation (GIC) and the United Arab Shipping
Company (UASC) – can prove that at least 51 per cent of the
beneficial interest in it is owned, directly or indirectly, by the
State of Kuwait and/or by a government institution of the
State of Kuwait and/or an individual, who is a resident of the
State of Kuwait and that company is controlled by the afore-
mentioned residents.
2. A further prerequisite for relief from German taxes under
paragraph 1 is that the company resident in the State of Kuwait
proves that it was not a principal purpose of the company or of
the conduct of its business or of the acquisition or maintenance
by it of the shareholding or other property from which the income
in question is derived to obtain any of such benefits to the
advantage of a person who is not a resident of the State of
Kuwait. Furthermore the company has to prove that more than
50 per cent of its gross income is not used, directly or indirectly,
to meet liabilities (including liabilities for interest or royalties) to
persons not entitled to benefits of this Agreement under sub-
paragraphs a) to d).
5. Irrespective of paragraph 4 the competent authorities of
both Contracting States shall to the extent provided under the
provisions of Article 26 exchange such information as is neces-
sary for carrying out the provisions of this Article and the appli-
cation of their respective internal laws concerning tax avoidance.
In case of disagreement between the competent authorities of
the two Contracting States, the procedure under Article 25 shall
be applied.
Citation to select or copy
Germany / Kuwait; BGBl. 2000 II S. 390; edition de-kuwait-2000-base | BGBl. 2000 II S. 390 | signed 1999-05-18 | published 2000-03-09 | Signed: 1999-05-18 | Gazette publication: 2000-03-09; article 23; English; unreviewed source text, current applicability unverified; /editions/de-kuwait-2000-base/en/articles/article-23/
Disclaimers
Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.
Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.
Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.
Noindex is not access control. This is a research preview, not a statement of authoritative or current law.
de-kuwait-2000-base | BGBl. 2000 II S. 390 | signed 1999-05-18 | published 2000-03-09 | Signed: 1999-05-18 | Gazette publication: 2000-03-09
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2000-03-09
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
1999-05-18
Edition notes and known limitations
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 1999-05-18; consent law 2000-02-27; gazette publication 2000-03-09. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 1998-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 14. Juli 1989, 2. August 2000. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Printed signature protocol retained separately and not merged into articles. This signed 1999-05-18 source replaces earlier convention signed 1987-12-04; exact cessation and transition require the entry article, not an edition-year inference. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Kuwait R-P P: 08.05.2025 KR KR. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
This source supplies German and English versions. The signing clause also identifies Arabic as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-kuwait-2000-base/. PDF page links identify pages, not verified paragraph correspondence.