1. UAE-KSA:
The first DTT signed between the Gulf countries was between Saudi Arabia and the UAE in May 2018; the text was published in March 2019; the DTT is applicable
from January 1, 2020. For more details see the
EY's overview.
2. Oman-Qatar:
The second DTT between the Gulf countries was signed by Oman and Qatar in November 2021; it is applicable
as of January 1, 2023. For more details see
the PwC's overview.
3. UAE-Kuwait:
On August 30, 2022 preliminary agreements about the conclusion of the UAE - Kuwait DTT were
reported. However, it was only yesterday, February 11, 2024, that the Kuwait News Agency (KUNA)
reported the signing of the final
version of the UAE-Kuwait DTT at a fiscal forum in Dubai as part of broader financial cooperation between the two states (an additional agreement to the Treaty
Protocol between the UAE and Egypt was also signed at the forum).
The forum was proceeded by the World Government Summit. The
report of the IMF Managing Director on tax transformation in the region mostly repeated the postulates of previous years. However, it is important that the first deputy Ruler of Dubai, Deputy Prime Minister and Minister of Finance of the UAE
confirmed that rapid global changes require the development of fiscal policies that meet the needs of national economies, and reiterated that this is at the core of the UAE's priorities.
4. KSA-Qatar:
On October 31, 2023, according to
information published by the Saudi Arabian government, the Council of Ministers initiated negotiations and the signing of a DTT with Qatar.(*)
5. Kuwait-Qatar:
On November 29, 2023, the Kuwait News Agency (KUNA)
reported that Qatar has approved a preliminary version of the Treaty with Kuwait.
6. KSA-Kuwait:
On January 31, 2024, according to a
report by the Saudi Press Agency, officials from Saudi Arabia and Kuwait met to discuss, among other things, their willingness to sign a DTT.(*)
7. UAE-Bahrain:
On February 5, 2024, the UAE Cabinet of Ministers
authorised the signing of a DTT with Bahrain, as well as an Agreement for investment cooperation and protection.
(*) #KSA Saudi Arabia's initiation of DTT negotiations with Qatar and Kuwait is also interesting in light of recent
proposals to adopt a blacklist of jurisdictions into the KSA's Income Tax Law, which were announced in October 2023 and are currently under consideration. It is proposed that any transaction involving a resident or permanent establishment in a jurisdiction that has
preferential tax regime will be subject to special provisions (including in relation to expense recognition, depreciation, withholding tax rates and transfer pricing rules). It is proposed that the tax regime will be considered preferential if it meets one of the conditions: a profit tax rate of less than 15%; no exchange of information agreement or lack of economic substance requirements (although some sources mention the application of these criteria on a cumulative basis; it will be interesting to see what the final provisions will look like). In the GCC region, these provisions could potentially affect the UAE, Bahrain, Qatar and Kuwait: i.e., if the income tax is below 15%, or there is an exemption for companies owned by GCC nationals.