Business Tax Act, 2009
Business Tax (Double Taxation Agreement) Regulations, 2009
Statutory Instrument 58 of 2009
- Not commenced
- [This is the version of this document at 8 November 2017.]
1. CitationThese Regulations may be cited as the Business Tax (Double Taxation Agreement) Regulations, 2009.
2. Declaration and effect of AgreementIt is hereby declared that the Government of the Republic of Seychelles and the Government of the State of Kuwait have entered into the agreement specified in the Schedule for the purposes of avoidance of double taxation and prevention of fiscal evasion and that the agreement shall have effect in relation to the tax imposed under this Act.
Agreement between the Government of the Republic of Seychelles and the Government of the State of Kuwait for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capitalThe Government of the Republic of Seychelles and the Government of the State of Kuwait,Desiring to promote their mutual economic relations through the conclusion between them of an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital;Have agreed as follows:
Article 1 – Persons coveredThis Agreement shall apply to persons who are residents of one or both of the Contracting States.
Article 2 – Taxes covered
Article 3 – General definitions
Article 4 – Resident
Article 5 – Permanent establishment
Article 6 – Income from immovable property
Article 7 – Business profits
Article 8 – Shipping and air transport
Article 9 – Associated enterprises
Article 10 – Dividends
Article 11 – Interest
Article 12 – Royalties
Article 13 – Capital gains
Article 14 – Dependent personal services
Article 15 – Directors' feesDirectors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or other similar organ of a company which is a resident of the other Contracting State shall be taxable only in the first-mentioned Contracting State.
Article 16 – Artistes and sportsmen
Article 17 – Pensions and annuities
Article 18 – Teachers and researchersAn individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who, at the invitation of the Government of the first-mentioned Contracting State or of a university, college, school, museum or other cultural institution in that first-mentioned Contracting State or under an official programme of cultural exchange, is present in that Contracting State for a period not exceeding two consecutive years solely for the purpose of teaching, giving lectures or carrying out research at such institution shall be exempt from tax in that Contracting State on his remuneration for such activity.
Article 19 – Government service
Article 20 – Students and trainees
Article 21 – Other income
Article 22 – Capital
Article 23 – Elimination of double taxation
Article 24 – Non-discrimination
Article 25 – Mutual agreement procedure
Article 26 – Exchange of information
Article 27 – Members of diplomatic missions and consular postsNothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or consular posts or an international organization under the general rules of international law or under the provisions of special agreements.
Article 28 – Entry into force
Article 29 – Duration and termination
Minister of National Development
For the Government of The Republic of Seychelles
|Mustafa J. Al-Shamall|
Minister of Finance
For the Government The State of Kuwait
History of this document
08 November 2017 this version