The following entities, whether Kuwaiti or Non-Kuwaiti, shall be excluded from the tax:

1. Governmental Entities.

2. Non-Profit Organizations.

3. International Organizations.

4. Pension Funds.

5. Investment Funds that are considered as ultimate parent entities.

6. Real estate investment vehicle that is considered as ultimate parent entity.

7. An entity -except with pension services entity- that is at least 95% directly owned by one or more entities mentioned in the above provisions and operates exclusively or primarily to hold assets or invest funds for the benefit of these investment entities.

8. An entity -except with pension services entity- that is at least 85% directly owned by one or more entities mentioned in the above provisions, provided that all of its income consists of dividends or equity gains or losses that are excluded from the calculation of net income or loss.

The executive regulation may define controls and conditions related to the application of this Article.