Exchange of information: treaty requires sharing and confidential use of tax information and assistance in tax collection.

The Protocol confines taxation of a permanent establishment's profits to receipts attributable to activities actually performed in the State where the permanent establishment is located, excludes outside sales or contract parts from that profit base, clarifies which Kuwaiti taxes are covered by the treaty, and replaces the exchange-of-information article with a detailed regime obliging competent authorities to exchange foreseeably relevant information, maintain secrecy and restricted use, use information-gathering measures on request, prohibit refusals based on bank or fiduciary status, and permit mutual assistance in revenue collection.

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