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<h3>Tax Rates</h3><table><thead><tr><th>Item</th><th>Article reference</th><th>Applicable Rates</th><th>Comments</th></tr></thead><tbody><tr><td>Dividends</td><td>Article 6 (Amends Article 10)</td><td>Not provided</td><td>The Protocol amends Article 10(3) of the Agreement to refer only to paragraph 1.</td></tr><tr><td>Interest</td><td>Article 7 (Amends Article 11)</td><td>Not provided</td><td>The Protocol amends Article 11(3) of the Agreement to refer only to paragraph 1.</td></tr><tr><td>Royalties</td><td>N/A</td><td>Not provided</td><td></td></tr><tr><td>Fees for Technical Services (FTS)</td><td>N/A</td><td>Not provided</td><td>N/A</td></tr><tr><td>Capital Gains : Immovable Property</td><td>N/A</td><td>Not provided</td><td></td></tr><tr><td>Capital Gains : Shares</td><td>N/A</td><td>Not provided</td><td></td></tr><tr><td>Construction PE</td><td>Article 4 (Amends Article 5)</td><td>Not provided</td><td>The Protocol amends Article 5(4) of the Agreement by deleting and replacing internal paragraph references. It does not state a threshold.</td></tr><tr><td>Services PE</td><td>N/A</td><td>Not provided</td><td>N/A</td></tr></tbody></table><h3>Other Relevant Provisions</h3><table><thead><tr><th>Provision</th><th>Article reference</th><th>Description</th></tr></thead><tbody></tbody></table>

Protocol Amending the Agreement between the Government of BRUNEI DARUSSALAM 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

The Government of His Majesty the Sultan and Yang Di-Pertuan of Brunei Darussalam and the Government of the State of Kuwait.

Desiring to amend the Agreement between the Government of Brunei Darussalam 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, signed at Kuwait on 13 of April 2009 (hereinafter referred to as "the Agreement").

Have agreed as follows:

Contents

Article 1

Article 2

Article 3

Article 4

Article 5

Article 6

Article 7

Article 8

Article 9

Article 10

Article 11

Article 12

Article 1

The existing sub-paragraph (b) of paragraph 3 in Article 2 of the Agreement is deleted and replaced by the following:

in the case of Kuwait:
1. Decree No. 3 of 1955 as amended by Law No. 2 of 2008.
2. Law No. 23 of 1961 of the Neutral Zone.
3. Law No. 19 of 2000 of the Supporting of National Employees.
(hereinafter referred to as "Kuwaiti tax").

Article 2

The existing sub-paragraph (c) (1) of paragraph 1 in Article 3 of the Agreement is amended by adding "and" after the (;)

Article 3

The existing sub-paragraph (a) of paragraph 1 in Article 4 of the Agreement is deleted and replaced by the following:

in the case of Kuwait, an individual who is present in Kuwait for a period or periods totaling in the aggregate at least 183 days within any 12 months period and a company or an entity which is incorporated in Kuwait;

Article 4

The existing paragraph 4 of Article 5 of the Agreement is amended:

by deleting the word "paragraph 6" and replacing with the word "paragraph 5"; and
in sub-paragraph (a), by deleting the word "paragraph 4" and replacing with the word "paragraph 3".

Article 5

The existing paragraph 3 of Article 9 of the Agreement is amended:

by adding "the" after "in"; and
by deleting the word "willful" and replacing with the word "wilful".

Article 6

The existing paragraph 3 of Article 10 of the Agreement is amended by deleting "The provisions of paragraphs 1 and 2 shall" and replacing with "The provisions of paragraph 1 shall".