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(1) This Agreement shall apply to taxes on income and on capital imposed on behalf of a Contracting State irrespective of the manner in which they are levied.
(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property as well as taxes on capital appreciation.
(3) The existing taxes to which this Agreement shall apply are in particular:
(a)in the case of the United Kingdom:
(i)the income tax;
(ii)the corporation tax;
(iii)the capital gains tax;
(hereinafter referred to as “United Kingdom tax”);
(b)in the case of Kuwait:
(i)the corporate income tax;
(ii)the contribution from the net profits of Kuwaiti shareholding companies payable to the Kuwaiti Foundation for Advancement of Science (KFAS);
(iii)the Zakat;
(hereinafter referred to as “Kuwaiti tax”).
(4) This Agreement shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of this Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.
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