GTL Summary:

Article 11 of Kuwait's Decree-Law 157 of 2024 establishes the methodology for computing the taxpayer's taxable income under the QDMTT framework. The calculation commences with the aggregation of the total net income or loss of all taxable entities that constitute the MNE group. A significant deduction is then made from this total for 'excluded income'. The value of this deduction is determined by the taxpayer's 'activity significance', a concept that is explicitly defined and detailed under the provisions of Article 10. This ensures the tax base is adjusted for substance-based income exclusions.