Appendix 1

Act on the double-tax agreement between Denmark and Kuwait

We, by God's grace, the Queen of the Danes, do our thing.

The parliament has adopted the following law, and we know that the following law has been approved by Parliament's consent :

§ 1. The provisions of the Convention of 22. June 2010 between the Kingdom of Denmark and Kuwait for the avoidance of double taxation and the prevention of tax evasion as regards income taxes and taxes, cf. Annex 1 applies to this country.

§ 2. The law shall enter into force on the day following the announcement in the law.

Paragraph 2. The law shall apply from the date of entry into force of the Agreement referred to in Section 1 in accordance with Article 29, and shall then have effect in accordance with Article 29.

§ 3. The law does not apply to the Faroe Islands and Greenland.

---

Appendix 1

The Agreement between the Government of the Kingdom of Denmark and the Government of the State of Kuwait for the avoidance of double taxation and the prevention of tax evasion in respect of income taxes and taxes ;

The Government of the Kingdom of Denmark and the Government of the State of Kuwait,

which seek to promote mutual economic relations, by incorporating a collective agreement to the avoidance of double taxation and the prevention of tax evasion as regards income taxes and assets ;

has agreed to :

ARTICLE 1

Persons covered by the Agreement

This Agreement shall apply to persons belonging to one or both of the Contracting Governments.

ARTICLE 2

Taxes covered by the Agreement

This Agreement shall apply to taxes on income and assets printed on behalf of a Contracting Government or by its political subdivisions or local authorities, without regard to how they are charged.

2. As income and property taxes shall be considered all taxes imposed on the entire income or assets or parts of income or assets, including taxes on profit by disposable or immovable property, taxes on the total of : they are paid or paid out of undertakings, as well as taxes on the increase in assets.

3. The applicable taxes on which the agreement is applied are in particular :

The Agreement shall also apply to taxes of the same or essential nature, which, after the date of signing of the Agreement by a Contracting Party, is printed as a supplement to or instead of the applicable taxes. The competent authorities of the Contracting Parties shall inform each other of significant changes made in their tax legislation.

ARTICLE 3

Common definitions

1. Except as otherwise in the context of the context, the following terms have been expressed in the following Agreement :

2. In the case of the application of the Agreement at any time, any term not defined in it, unless otherwise provided by the consistency, is given the importance it attaching at this stage of the date of the Contracting Party ; legislation relating to the taxes applied by the Agreement, with any significance in the tax havens used in this Contracting Government, must take precedence over the meaning of the expression in other laws used in this Convention ; Contracting Government.

ARTICLE 4

Tax Home

1. In this Agreement, the expression ' shall mean a person belonging to a Contracting Government ' means :

a) In Kuwait, a natural person who has his residence in Kuwait and is a Kuwaiti national, and a company that has been set up in Kuwait.

b) In Denmark, any person who, in accordance with the laws of Denmark, is taxable on account of domicile, domicile, seat of management, or any other criteria of similar nature. However, this expression does not include a person who is taxable in Denmark only of income from sources in Denmark or of the wealth which is in Denmark.

2. For the use of paragraph 1, ' a person resident in a Contracting Government ` shall include all of the following :

a) the Government of this Contracting Government and any of its political subdivisions or local departments ;

b) any governmental institution which has been set up in this Contracting Government under public law, such as company, national bank, fund, authority, arson, agency or other similar unit ;

c) any entity established in this Contracting Government if the entire capital of the entity is obtained by this Contracting Government or any of its political subdivisions or local authorities or by any governmental institution as defined ; in (a) or (b) of this paragraph, together with other states. This provision shall be solely applicable to the part of the unit that corresponds to the share of the unit owned by a Contracting Government or any of its political subdivisions or local authorities or by any governmental institution as defined in : in this paragraph (a) or (b) ;

d) in Denmark : a legal person established in Denmark, in accordance with the law in Denmark, with the aim of offering pensions and other similar services to natural persons, and which are generally exempt from taxation in Denmark.

3. If a natural person after the provisions of paragraph 1 is established in both Contracting Governments, his status shall be determined in accordance with the following rules :

a) he shall be considered only to be resident in the Contracting Government where he has a permanent residence at his disposal. If he has a permanent residence at his disposal in both Contracting Governments, he shall be considered only to be a resident of the Contracting Government with which he has the strongest personal and economic relations (the centre of its life interests) ;

b) in the event that it cannot be decided in which Contracting Government he has the centre of its life interests, or if he does not have a permanent residence in any of the Contracting Governments, he shall be considered only to be at home in the Contracting Party, the state in which he usually has a stay ;

c) if he is usually resident in both Contracting Governments, or if he does not have such a residence in any of them, he shall be deemed to be only indigenous to the Contracting Government where he is a national ;

d) where his status cannot be determined in accordance with the provisions of (a) to (c), the competent authorities of the Contracting Parties shall decide on the question by mutual agreement.

4. If a non-physical person after the provisions of paragraph 1 is established in both Contracting Governments, it shall be considered only to be resident in the Contracting Government in which its true management has its seat.

Article 5

Fixed operational location

1. In this Agreement, the term ' firm operating location ' means a regular business location by means of an undertaking ' s business activity in whole or in part.

2. The term ' firm operating location ` shall include in particular :

a) a place where an undertaking is led ;

b) a branch ;

c) an office ;

d) a factory ;

(e) a workshop ; and

(f) a mine, an oil or gas source, a quarry or any other place where natural occurrences are to be extracted.

3. A construction site or an angs-, co-birth or installation work or supervisory activities carried out in a Contracting Government shall constitute only one firm operating location where such a place, work or activity is maintained in a Contracting Government ; Period of more than nine months.

4. Services, including consultancy or management assistance provided by an undertaking in a Contracting Government by means of employees or other personnel involved in the operation of this operation in the other Contracting Government, constitute only one permanent ; operation where the undertaking is maintained in one or more periods that comprise more than nine months in the event of any 12 months period.

5. An installation, drilling, or a ship used in the case of the investigation of natural occurrences, is only a fixed operation site where the goods or activity continues for more than 12 months. Activity carried out by an undertaking connected with another undertaking shall be deemed to have been exercised by the undertaking, which is linked to the activity of the undertaking :

a) the substance of the latter is essentially the same as that of the latter undertaking ; and

b) relate to the same project or the same operation ;

unless the activities concerned are carried out simultaneously. For the purposes of this paragraph, undertakings shall be deemed to be connected when the same persons, directly or indirectly, are part of the management of the control or capital of the undertakings.

6. Notwithstanding the previous provisions of this Article, ' regular farm ` shall not be considered to include :

a) the use of the information solely for the purposes of storage, exhibition or delivery of the goods of the undertaking ;

b) the maintenance of a stock-related undertaking solely for the purposes of storage, exhibition or extradition ;

c) the maintenance of a stock-related undertaking solely for the purpose of processing at another undertaking ;

d) the maintenance of a fixed establishment solely for the purpose of making purchases of goods or collecting information for the undertaking ;

(e) the maintenance of a fixed establishment solely for the purpose of exercising any other undertaking of preparatory work or of a helping undertaking ;

(f) maintaining a firm business location solely to exercise any combination of the activities referred to in (a) to (e), provided that the overall business of the business as a result of this combination is of preparatory or of a helping nature.

7. If a person who is not such an independent representative as referred to in paragraph 8 is acting in a Contracting Government on behalf of an undertaking in the other Contracting Government, this undertaking, notwithstanding the provisions of paragraphs 1 and 2, shall be deemed to have been deemed to have been : have a permanent farm operating in the former Contracting Government with regard to any undertaking which this person undertakes, if this person has and usually carries out in the former State a power of attorney to conclude contracts ; the name of the undertaking, unless this person is limited to such activity, as mentioned in : paragraph 6 and which, if carried out by means of a fixed place of business, would not make this permanent place of business for a fixed farm basis in accordance with the provisions of this paragraph.

8. An undertaking in a Contracting Government shall not be deemed to have a permanent operation in the other Contracting Government, simply because it operates in this other Contracting Government by means of a mediator, Commission or any other independent state, representative, provided that such persons act within the framework of their customary business activities. However, where such representative activities are carried out exclusively or almost exclusively on behalf of this undertaking or other undertakings which are controlled by it or have a controlling interest, he shall not be regarded as a single person ; an independent representative in the meaning of this type.

9. The fact that a company belonging to a Contracting Government shall check or be checked by a company belonging to the other Contracting Government or operating in this other Contracting Government, (either through a fixed operating facility or otherwise) shall not, in itself, mean that the single company is considered to be a firm operating facility for the other.

ARTICLE 6

Income of immovable property

1. Income, as a person resident in a Contracting Government, the acquiring of real estate (including the income of land or forestry) situated in the other Contracting Government may be taxed in this other Contracting Government.

2. The term ' immovable property ` shall be attached to the importance it has in the law of the Contracting Government where the property in question is situated. In all cases, the expression shall include accessories to immovable property, crew and tools used in land and forestry, rights on which the provisions of the Civil Code of Real Estate are applicable, the right of use to immovable property and the right to access ; variable or flat-rate payments as remuneration for the exploitation of, or the right to use, mineral deposits, sources and other natural occurrences. Ships and planes shall not be regarded as immovable property.

3. The provisions of paragraph 1 shall apply to income derived from direct use, renting or use in any other form of immovable property.

4. The provisions of paragraph 1 and 3 shall also apply to the income of fixed property belonging to an undertaking and on the income of real estate used for the exercise of free trade.

Article 7

Deserts on business

1. Profit to be paid by an undertaking in a Contracting Government may only be taxed in this Contracting Government unless the undertaking operates in the other Contracting Government by means of a fixed farm which is situated in this Contracting Party, other Contracting Government. If the undertaking operates or has operated in business in this way, the profits of the undertaking may be taxed in the other Contracting Government, but only the part thereof which may be attributed to this firm operating location.

2. If an undertaking in a Contracting Government operates in the other Contracting Government through an established operating location, then, except in paragraph 3, the provisions of paragraph 3 shall result in other, in each Contracting Government, to this fixed ; the operation takes place the profit which it could be expected to achieve if it had been a free and independent undertaking engaged in the same or similar undertaking on the same or similar conditions, and which, under the conditions of such conditions, were carried out ; relationships did business with the operation of which is a firm operating facility.

3. On the establishment of a fixed operating site, it shall be permitted to deduction the deductible costs incurred for the fixed operating site, including the management and administration of the administration, whether or not incurred ; costs have been held in the state in which the fixed operating location is situated or elsewhere.

4. No profit should be carried out to a fixed operating point simply because this fixed operation has carried out the purchase of goods for the undertaking.

5. If it has been customary in a Contracting Government to employ the profit of a fixed operating site on the basis of a breakdown of the total profits of the undertaking between its various departments, nothing shall be prevented by paragraph 2 ; this Contracting Government to employ the taxable profit on the basis of such a common distribution. However, the chosen distribution method must be such that the result will be in accordance with the principles laid down in this Article.

6. If the information available to the competent authority of a Contracting Government is insufficient to employ the profit to be taken to a firm operating point of a person, nothing in this Article shall affect it ; the application by the competent authority of the Contracting Government of the laws, regulations or rules of this Contracting Government concerning the application of the tax to this firm, by means of a discretionary operation by the competent authority of this Contracting Government ; the profits which are taxable for the fixed operating place, provided that such legislation or rules shall be applicable in the light of the information available to the competent authority in accordance with the principles laid down in this Article.

For the purposes of applying the preceding paragraphs, the profits being carried out to the permanent farm shall be replaced by the same year, unless there is good and full reason for using a different approach.

8. Profit for income and benefits provided for in other articles of this Agreement shall be subject to the provisions of these other articles not subject to the provisions of this Article.

ARTICLE 8

ship and air services

1. Profit to be taxed in this Contracting Government by an undertaking in a Contracting Government by a contracting State in the operation of ships and aircraft in international traffic.

2. In the application of this Article, the use of ships and aircraft in international traffic shall include all of the following :

a) profits on the inlet of ships or aeroplanes (barebo Charter),

b) the use, availability or rental of containers (including trailers and similar equipment for the carriage of containers) used for the carriage of goods or goods,

where such equipment is used, such use, such on-call or rental, shall be aflinked to the operation of ships or aircraft in international traffic.

3. The provisions of paragraph 1 and 2 shall also apply to profits by participating in a pool, a business community or an international operation organisation.

4. In cases where undertakings from several countries have agreed to operate ships-or air carriers in international traffic together in the form of a business community, the provisions of this Article shall apply only to that part of the profit, which : corresponds to the proportion of this business community owned by an undertaking in a Contracting Government.

Article 9

Bundling Undertaking

1. If

a) an undertaking in a Contracting Government, directly or indirectly, in the management of, control of, or capital of an undertaking in the other Contracting Government, or

b) the persons directly or indirectly participate in the management, control of, or capital of both an undertaking in a Contracting Government and in the other Contracting Government,

and in some of these cases between the two undertakings, they have been agreed or set out in terms of their business or financial relations that deviate from the terms and conditions agreed between independent undertakings, may any profit which, if these conditions had not been in place, would have been attributed to one of the undertakings, but which, because of these conditions, has not been added to this, shall be taken into account for the profit and tax of this undertaking.

2. If a Contracting Government to the profit of a undertaking in this Contracting Government is to include, and in accordance with it, tax due to be taxed by the other Contracting Government in this other Contracting Government, " State " means the profits which would have been attributed to the undertaking in the former Contracting Government if the conditions agreed between the two undertakings would have been the same as would have been agreed between ; independent undertakings shall, appropriate, make an appropriate Contracting Government ; the adjustment of the amount of the tax which is calculated by the profit. The other provisions of this Agreement and the competent authorities of the Contracting Parties shall, where necessary, consult each other, shall take due account of the other provisions of this Agreement and, if necessary, consult each other.

Article 10

Exbooty

1. Exboots paid by a party belonging to a Contracting Government to a person belonging to the other Contracting Government may be subject to tax in this other state.

However, such dividended may also be taxed in the Contracting Government where the company that pays the proceeds is based, and in accordance with the law of this State, but if the rightful owner of the proceeds is established in the other Contracting Government, the tax thus laid down shall not exceed :

a) 0%. of the gross amount of the yield if the rightful owner is a company (with the exception of a stakeholder), which directly owns at least 25%. the capital of the undertaking which pays the proceeds and has owned this part of the capital during an uninterrupted period of at least one year and the yield shall be fixed within that period ;

b) 0%. for the gross amount of the yield if the legal owner of the proceeds is the other Contracting Government or any government institution or any entity that is resident in the other Contracting Government in accordance with Article 4 (1). (c) 2 (a)-(c).

c) 5%. of the gross amount of the yield if the rightful owner is a pension fund or other similar institution which provides pension schemes in which natural persons can participate in the provision of retirement benefits when such pensions are provided ; the other similar institution has been created, tax-approved and verified in accordance with the law of this other State ;

d) 15%. of the gross amount of the yield in all other cases.

The competent authorities of the Contracting Parties shall set out by mutual agreement the detailed rules for the implementation of these restrictions.

This paragraph shall not affect access to taxing the company of profits from which the yields are paid.

3. The term ' yield ` means the income of shares, 'jouissance' shares or 'jouissance' rights, those of mine agents, the units or other non-debt entitlements and which give the right to share in profits ; and the income of other company rights which have been subject to the same tax treatment as the income of shares in accordance with the law of the State in which the company that carries out the encoding is based.

4. The provisions of paragraph 1 and 2 shall not apply where the rightful owner of the provider, which is indigenous to a Contracting Government, operates in the other Contracting Government where the profit-paying company is indigenous, through a there is a fixed operating site and the stock holding which is based on the payment of the proceeds shall have a direct connection with such a fixed operation location. In this case, the provisions of Article 7 shall apply.

5. If a company belonging to a Contracting Government acquires profits or income from the other Contracting Government, then the other Member State may not impose any tax on the benefits provided by the company, unless the proceeds are paid ; a person resident in this other State, or unless the shareholding which is based on the payment of the proceeds, has a direct connection with a fixed farm operating in this other State, or to the company of the company, or non-unloaded profits on the company's non-defledable profits, even though it is : derive profit or not, wholly or partially, of profit or income derived from that other state.

6. If a Contracting Government has collected withholding tax with a higher amount than the tax to be imposed in accordance with the provisions of this Agreement, the application for repayment of the excess amount shall be submitted to the competent authority in this Agreement ; within a period of three years after the expiry of the calendar year in which the tax is charged. The repayment shall be made within a six month period from the date on which the request was submitted to the competent authority. The six-month period may be extended if both Contracting Governments agree that the necessary documentation is not submitted to the competent authority of the first state.

Article 11

Interesters

1. Interest who originate from a Contracting Government and shall be paid to a person resident in the other Contracting Government and which is the rightful owner of such interest may only be taxed in this other Contracting Government.

2. The term ' interest ` as used in this Article means the income of debt claims of any kind, whether they are protected by the mortgage or not, and whether they contain a right to a proportion in the debtor's profit or not, and in particular : the income of the public debt and the income of debt securities or depreciation, including agiobelation and benefits attached to such debt certificates, debt securities or rewrites, as well as income that are subject to the same tax ; treatment as income of the pen loans in accordance with the tax laws in the Contracting Government from which : the income from the earlstone.

3. The provisions of paragraph 1 shall not apply where the rightful owner of the interest belongs to a Contracting Government by the other Contracting Government of which the interest is derived from a fixed farm, in the case of the Contracting Parties, this other Contracting Government and the debt which is due to the interest paid shall be directly related to such fixed operating conditions. In this case, the provisions of Article 7 shall apply.

4. interest shall be deemed to be derived from a Contracting Government when they are paid by a person resident in this Contracting Government. If the person who pays interest rates, whether he is the resident of a Contracting Government or not, has a fixed operation location in a Contracting Government for which the debt ratio, the interest rate paid, was the diocese, and such interest whereas, however, such interest shall be deemed to have been taken from the Contracting Government where the fixed operating location is situated.

5. If a specific link between the person paying and the rightful owner of the interest or between them and a third person has resulted in interest rates in relation to the debt debt in respect of which they are paid exceeds the amount which would be The provisions of this Article shall apply only to the latter amount, as agreed between the paying and the rightful owner, as provided for in this Article. In this case the excess amount shall be subject to tax in accordance with the legislation of each Contracting Government, taking into account the other provisions of this Agreement.

Article 12

Royalties

1. Royalties arising from a Contracting Government and paid to a person resident in the other Contracting Government may be subject to tax in this other Contracting Government.

However, such royalties may also be taxed in the Contracting Government from which they originate and, in accordance with the law of this Contracting Government, but if the rightful owner of the royalty amount is a resident of the other Contracting Government, it may, therefore, be subject to the law, inlaid taxes shall not exceed 10%. of the gross amount of the royalty amount.

3. The term " royalties " used in this Article shall mean the payment of any kind received in payment for the use of, or the right to use, any copyright to a literary, artistic or scientific work, including : film and work on films, tapes or other means of rendering for television or broadcasting, any patent, trade mark, design, pattern or model, drawing, secret formula or method of manufacture, or information (know how) on industrial, commercial or scientific experience.

4. The provisions of paragraph 1 and 2 shall not apply where the legal owner of a Contracting Government belongs to a Contracting Government, operates in the other Contracting Government, from which the royalty amount originates, through a fixed ; the place of operation situated in this other Contracting Government, and the right or property of the property of the unpaid royalties, shall have a direct connection with such a fixed operation. In this case, the provisions of Article 7 shall apply.

5. Royalties shall be deemed to originate from a Contracting Government when they are paid by a person resident in this Contracting Government. If the person who pays the royalty amount, whether he is a resident of a Contracting Government or not, has a fixed operation location in a Contracting Government in connection with which the obligation to pay the royalty amount was set, and such whereas, however, royalties are the responsibility of such a holding shall be deemed to be derived from the Contracting Government in which the fixed operating location is situated.

6. If a special connection between the person who pays and the rightful owner of the royalty amount or between them and a third person has caused the amount of the royalty to be seen in relation to the use, privilege or information, for which it has been paid ; in excess of the amount which would have been agreed between the paying and the rightful owner, where such a connection had not been provided, the provisions of this Article shall apply only to the latter amount. In this case the excess amount shall be subject to tax in accordance with the legislation of each Contracting Government, taking into account the other provisions of this Agreement.

ARTICLE 13

Capital gains

1. Profit, as a person belonging to a Contracting Government, the transferee of the immovable property as referred to in Article 6, situated in the other Contracting Government, may be taxed in this other Contracting Government.

2. Proceeding by Disposal of the Pipe Property, which forms part of the business asset in a fixed operating facility in a Contracting Government, in the other Contracting Government, including the profit of the disposal of such a fixed operating location, (separately or jointly with the entire undertaking) may be taxed in this other Contracting Government.

3. Proceeding to be carried out by an undertaking in a Contracting Government by the transfer of ships or aircraft used in international traffic, or by any movable property associated with the operation of such ships or aeroplanes, it may be taxed only in this Contracting Government.

4. Proceeding to the disposal of all other assets other than those referred to in paragraph 1, 2 and 3 may only be taxed in the Contracting Government where the dispos; of the Disposal is situated.

5. In cases where undertakings from several countries have agreed to operate ships-or air carriers in international traffic together in the form of a business community, the provisions of paragraph 3 shall apply only to the part of the profit which is equivalent to that ; to the share of this business community owned by an undertaking in a Contracting Government.

ARTICLE 14

Personal work in employment relations

Subject to the provisions of Articles 15, 17, 18, 19 and 20, other, salary, salary and other similar charges may be obtained by a person resident in a Contracting Government for personal work, only subject to taxation in this Contracting Party ; state, unless the work has been carried out in the other Contracting Government. If the work has been carried out there, it may be taxed in this other Contracting Government by the remuneration obtained.

Notwithstanding the provisions of paragraph 1, payment acquired by a person resident in a Contracting Government for personal work carried out in the other Contracting Government shall be taxed only in the first Contracting Government if :

a) the consignee residing in one or more of the periods which together does not exceed 183 days in a 12-month period beginning or ends in that fiscal year, and

b) the remuneration shall be paid by or for an employer not resident in the other Contracting Government ; and

c) the remuneration is not borne by a fixed operating location or a fixed place which the employer has in the other Contracting Government.

Notwithstanding the previous provisions of this Article, remuneration for personal work carried out on board a ship or aircraft used in international traffic of an undertaking in a Contracting Government may be taxed in this Contracting Government.

Article 15

Constyliorar management

governing orders and other similar charges obtained by a person resident in a Contracting Government, in his capacity as a member of the Management Board or a similar body for a party belonging to the other Contracting Party, State may be taxed only in the first Contracting Government.

Article 16

Artists and sportsmen

Notwithstanding the provisions of Article 15, income acquired by a person resident in a Contracting Government as performers such as theatre, film, radio or television shows or musician, or as a sportscader at his / her personally engaged in activities as such in the other Contracting Government shall be taxed in this other Contracting Government.

2. If the income of personal business practised by performers or sportsmen does not belong to the artist or the sportsman himself, but another person, this income, regardless of the provisions of Articles 7 and 14, may be taxed ; in the Contracting Government where the operation of the artist or the sportsmen or sportsmen is exercised.

3. The provisions of paragraph 1 and 2 shall not apply to income obtained by performers or sportsmen or sportsmen belonging to a Contracting Government in person who are personally engaged in activities as such in the other Contracting Government, if : Whereas the visit to this other Contracting Government is essentially supported by public funds from the former Contracting Government, including the means by any of its political subdivisions or by local authorities or by the institutions, or on income acquired by a non-profit-seeking organization in the case of such such as : activities, provided that no part of its income is paid to or otherwise available for personal benefit to its owners, members or members.

Article 17

Pensions, social services and similar payments

1. Payments as a natural person resident in a Contracting Government shall receive, in accordance with the social security law of the other Contracting Government or by any other scheme from the funds provided for by this other State or of any other Member State, the relevant political subsection or local authority may be taxed in this other state.

2. Unless the provisions of paragraph 1 and Article 18 (2) of this Article are otherwise provided, pensions may and other similar charges arising from a Contracting Government and shall be paid to a person resident in the other Contracting Party ; State, whether it is for the past services or not, is taxed only in the other Contracting Government. However, such pensions and other similar charges may be taxed in the first Contracting Government if :

a) contributions paid by the beneficiary to the pension scheme were deduced in the recipient ' s taxable income in the former Contracting Government under the law of this State ; or

b) contributions paid by an employer were not a taxable income for the beneficiary of the former Contracting Government in accordance with the law of this State.

3. Pensions must be considered to be derived from a Contracting Government if they are paid out by a pension fund or other similar institution which provides pension schemes to which natural persons can join in order to secure pensions ; when such a pension fund or other equivalent institution has been established, tax-recognized and controlled in accordance with the law of this Contracting Government.

Article 18

Publicity

3. The provisions of Articles 14, 15 and 17 shall apply to salaries, wages and other similar remuneration and to pensions paid for the performance of the business operations operated by a Contracting Government or belonging to them ; political subsection or local authority.

Article 19

♪ Teachers and scientists ♪

A natural person who is, or like, immediately before visiting a Contracting Government, was in the other Contracting Government and which, on the invitation of the former Contracting Government or from a university, institute or university, was invited to be at the invitation of the former Contracting Government or from a university, training school, the museum or other cultural institution of the former Contracting Government or under an official cultural exchange programme shall be residing in this Contracting Government for a period not exceeding two consecurely years, with only the one in question. the purpose of teaching, to provide lessons or to carry out research at such an institution, shall : be exempt from taxation in this Contracting Government of its remuneration for this company, the remuneration of which is derived from sources outside that state.

Article 20

Students

1. Amount, as a student or apprentice, which is, or which, immediately before visiting a Contracting Government, was established in the other Contracting Government and which is residing in the former Contracting Government exclusively in studies-or training purposes shall not be taxed in this State for training, study or training shall not be taxed in this state, provided that such amounts derive from sources outside that state.

2. For grants, scholarships and remuneration from employment which are not covered by unit 1, a student or apprentice as referred to in paragraph 1 shall be entitled to the same exemption, facilitation or other such training, reductions in taxation, which are granted to persons belonging to the Contracting Government to whom the person concerned is situated.

Article 21

Other income

1. Income, acquired by a person resident in a Contracting Government which has not been processed in the prior articles of this Agreement, irrespective of where they originated, only be taxed in this state.

2. The provisions of paragraph 1 shall not apply to income, with the exception of the income of real estate as defined in Article 6, paragraph 2, if it is operating in the other by a Contracting Government of such income ; Contracting Government through an established operating location, and the right or property of the paid income, has a direct connection with such a fixed operating location or location. In this case, the provisions of Article 7 shall apply.

Article 22

Formue

1. Formue of immovable property as referred to in Article 6, owned by a person resident in a Contracting Government and situated in the other Contracting Government, may be taxed in this other Contracting Government.

2. Formue made up of a pious wealth constituting a part of the business asset in a firm operating facility in a Contracting Government in the other Contracting Government may be taxed in this other Contracting Government.

3. Formue consisting of ships and aeroplanes used in international traffic of an undertaking in a Contracting Government and the assets associated with the operation of such ships and aircraft may only be taxed in this Contracting Government.

All other assets belonging to a person belonging to a Contracting Government may only be taxed in this Contracting Government.

5. In cases where undertakings from several countries have agreed to operate ships-or air carriers in international traffic together in the form of a business community, the provisions of this Article shall apply only to the part of the goods which are equivalent to that ; to the share of this business community owned by an undertaking in a Contracting Government.

Article 23

Repeal of double taxation

Paragraph 1. The legislation in force in the Contracting Governments must continue to apply to taxation in the respective Contracting Governments unless, in this Agreement, it is agreed that the rules that result in other measures are agreed.

2. It is agreed that double taxation should be avoided in accordance with the following paragraphs in this Article :

ARTICLE 24

Non-discrimination

1. Member State nationals of a Contracting Government may not be subject to any tax or related claims in the other Contracting Government which are different or more cumbersome other than the taxation and related requirements of nationals of this other ; State under the same conditions, or shall be subject to notification.

2. The taxation of a fixed farm operating in a Contracting Government of the other Contracting Government may not be less advantageous in this other state than the taxation of undertakings in this other state by the practice of the same establishment. This provision should not be interpreted as binding a Contracting Government to allow persons belonging to the other Contracting Government, the personal tax benefits, relaxes and reductions, as the result of : a conjugal position or a grievout duty to the families of people who are indigenous to their own territory.

3. Undertaking in a Contracting Government whose capital is owned or controlled directly or indirectly, by one or more persons belonging to the other Contracting Government, may not be subject to any of the former state ; the taxation or related requirements, which are different or more cumbersome than the taxation and related requirements laid down by other similar undertakings in the former or may be subject to the conditions of the latter.

4. Irrespective of the provisions of paragraphs 1, 2 and 3, nothing in this Article shall affect the right of each Contracting Government to grant exemption or reduction of taxation according to its internal laws, regulations or administrative practice ; its own nationals belonging to this Contracting Government. Such exemption or reduction shall not, however, apply in respect of that part of the capital of companies owned by persons who are nationals of the other Contracting Government.

5. Nothing in this Article shall be construed as laying a legal obligation on a Contracting Government to extend to persons belonging to the other Contracting Government, the benefit of any treatment, preferential treatment or rights which may be : be granted to any other Contracting Government or persons resident in this State, through the formation of a customs union, economic union, special agreements or a free trade area, or in force of any regional or sub-regional scheme, all or principally related to capital movement and / or taxation, as it is ; the Contracting Government shall be subject to the former Contracting Government.

Article (6), notwithstanding the provisions of Article 2, the provisions of this Article shall apply to taxes of any kind and description.

ARTICLE 25

Procedure for the conclusion of reciprocal agreements

1. If a person considers that the measures taken by one or both of the Contracting Governments of him may or may not comply with the provisions of this Agreement, he may, irrespective of the legal means, may or may not be in accordance with the provisions of this Agreement. Whereas, in the internal legislation of these Contracting Parties, the competent authority of the Contracting Government may be subject to the competent authority of the Contracting Government where he is established or, where his case is subject to Article 24, paragraph 1, for the competent authority ; the authority of the Contracting Government where he is a national. The matter must be brought before three years from the date on which the first notification has been given to the measure resulting from a tax that is not in accordance with the provisions of the Agreement.

2. The competent authority must, where the notice appears to be justified, and if it is not itself able to reach a reasonable solution, the matter may seek to resolve the matter by mutual agreement with the competent authority of the other Contracting Government for the purpose of the latter ; to avoid taxation that is not in accordance with the Agreement. Any contract concluded shall be implemented without regard to the time limits laid down in the internal legislation of the Contracting Parties.

3. The competent authorities of the Contracting Parties shall seek mutual agreement to resolve any difficulties or dubious issues arising from the interpretation or application of the Agreement. They can also negotiate the avoidance of double taxation in cases not referred to in the Agreement.

4. The competent authorities of the Contracting Parties may enter directly to each other, including through a joint commissions composed of them themselves or their representatives, with a view to the conclusion of an agreement in accordance with them ; previous paragraphs.

Article 26

Exchange of information

1. The competent authorities of the Contracting Parties shall exchange such information, which may be foreseen in order to implement the provisions of this Agreement or to the administration or enforcement of internal legislation relating to : taxes of any kind and name imposed on behalf of the Contracting Governments, their political subdivisions or local authorities, provided that such taxation does not conflict with the agreement. The exchange of information shall not be limited by Articles 1 and 2.

2. Any information received by a Contracting Government shall be treated as secret in the same manner as the information obtained under this State's internal legislation and may be granted only to persons or authorities (including courts and ' administrative authorities ' involved in the equation, collection, recovery or prosecution of the taxes covered by paragraph 1 or of the inspection of the aforementioned taxation. Such persons or authorities may use this information only for the purposes mentioned. You may communicate information to the public or to court rulings.

The provisions of paragraph 1 and 2 shall in no case be interpreted as to require a Contracting Government to be required to :

a) to carry out administrative areas which are contrary to the legislation and the management practices of this or other Contracting Government ;

b) to communicate information which cannot be obtained under the legislation or the normal management practices of this or other Contracting Government ;

c) to communicate information which would reveal any business, business, industrial, commercial or professional secret or method of manufacture, or if disclosure would dispute the general interest (order public).

4. If a Contracting Government asks for information pursuant to this Article, the other Contracting Government shall implement the measures which are available to obtain the requested information, whether or not the other Member State may not have needs ; for this information for its own taxation purposes. The obligation laid down in the preceding period shall be subject to limitations in paragraph 3, but in no case must such restrictions be interpreted in such a way as to enable the Contracting Government to refuse information simply because it is not : not himself has any tax interest in such information.

In no case, the provisions of paragraph 3 may be interpreted as allowing a Contracting Government to refuse information simply because the information is to be obtained from a bank, another financial institution, representative or the person acting as authorised or as a guaran or because the information relates to ownership of a person.

ARTICLE 27

Different rules

The provisions of this Agreement shall not be interpreted in such a way that they restrict any exemption, exemption, deduction, repayment or other dismissals which are now to be granted, either :

a) the legislation of a Contracting Government on the determination of the tax to be imposed by this Contracting Government ; or

b) after any other special scheme for taxation in the context of economic or technical cooperation between the Contracting Governments.

The competent authorities of each Contracting Government may give instructions in order to implement the provisions of this Agreement.

Article 28

Members of diplomatic representations and consular posts

Nothing in this agreement must touch on the tax benefits which members of a diplomatic representation, a consulary office or an international organisation enjoy the general rules or special agreements of the international law.

ARTICLE 29

Entry into force

Each Contracting Party shall inform the other of the implementation of the constitutional conditions for the entry into force of this Agreement. The Agreement shall enter into force on the date of the last of these orient information and its provisions shall then have effect in both Contracting Governments :

a) in the case of withholding tax, on amounts paid or rewritten on or after the 1. of January of the year in which the agreement has been signed ;

b) in the case of other taxes, for taxable periods starting or after 1. of January of the year after the year in which the agreement is signed.

Article 30

Duration and Termination

This agreement must remain in force until it is terminated by a Contracting Government. Each Contracting Government may terminate the Agreement by means of diplomatic means giving notice of termination of the Agreement at least six months prior to the end of any calendar year following the expiry of a period of five years from the year in which : The Agreement shall enter into force. In this case, the Agreement shall cease to have effect in both Contracting Governments,

a) in the case of withholding tax, on amounts paid or rewritten on or after the 1. of the year in which notification is given on termination ;

b) in the case of other taxes, for taxable periods starting or after 1. of January of the year after the year in which the notice is announced.

The President of the European Union has signed the Agreement, duly authorised by their respective governments, signed by this Agreement.

Done at Kuwait,

the 10th. Rajab 1431 H,

which corresponds to the 22nd. June 2010,

in two copies in Danish, Arabic and English, all texts of the same validity. In the event of deviation, the English text must be decisive.

Protocol

In the signing of the Agreement to exempt double taxation and prevent tax evasion as regards income taxes and property taxes between the government of the government of Kuwait and the Government of the Kingdom of Denmark, the undersigned agree ; the following provisions shall form an integral part of the Agreement :

1. Articles 5 and 7

It is agreed that when an undertaking in a Contracting Government sells goods or operates in the other Contracting Government by means of a fixed operating site, the fixed operating establishment must be fixed only on the basis of that which is situated in the territory of the other Contracting Party ; remuneration which may be applied to the current establishment in the firm operating place of such sales or business. In particular, as regards contracts for inspection, supply, assembly or plant of industrial or commercial or property or public works, where an undertaking has a fixed operating site, such a fixed operating site must, in particular, be carried out ; Profit shall be determined only on the basis of the part of the contract which has been effectively carried out by the permanent operating place of the State in which the fixed operating location is situated. The only thing that relates to the part of the contract carried out by the principal office of a company may be taxed only in the State in which the undertaking is indigenous.

2. To Article 10, paragraph 2 (a)

It is agreed that when the proceeds are paid for by a company belonging to Denmark, to a company belonging to Kuwait, and this yield according to the current legislation in Kuwait is taxed with a rate lower than 15 pct;, so may it be possible to use a rate lower than 15 pcrates. Denmark shall levy a tax that does not exceed 15%. the gross amount of the yield.

3. Articles 11 and 12

A Contracting Government may, in accordance with the tax laws in force in this State, taxing interest and royalties paid by a party belonging to this Contracting Government to a company, a trust, a stakeholder, or any other legal person who is resident in the other Contracting Government when :

a) More than 50%. by the capital or of the votes of the company, the trust, the interested party or the other legal person who receives these interest or royalties, is owned or controlled directly or indirectly by a person or connected company ; trusts, stakeholders or other legal persons who are not indigenous to one of the Contracting Governments or in the European Union or the European Economic Area, and

b) whereas such interest or royalties would not be subject to a reduced rate of tax or tax exemption from the Contracting Government from which they come, in accordance with the provisions of a double-tax agreement or other Agreement concluded between this State ; and other States or jurisdictions, if they were paid directly from the company in the first state to any or connected companies, trusts or stakeholder or other legal persons who are directly or indirectly participating in ; the ownership or control of the company to which such interest or royalties are paid.

For the purpose of applying these provisions, the term ' linked companies, trusts or stakeholders or other legal persons ' means companies, trusts or stakeholder or other legal persons in which the same people participate ; directly or indirectly in the management, control or capital.

The President of the European Union has signed the Agreement, duly authorised by their respective governments, signed by this Agreement.

Done at Kuwait,

the 10th. Rajab 1431 H,

which corresponds to the 22nd. June 2010,

in two copies in Danish, Arabic and English, all texts of the same validity. In the event of deviation, the English text must be decisive.