GTL Summary:

Article 12 of Decree-Law No. 157 of 2024 outlines the fundamental calculation for the Qualified Domestic Minimum Top-Up Tax (QDMTT). The tax is determined by multiplying the applicable tax rate by the taxable income. It specifies two key conditions under which the tax liability will be zero: firstly, if the income excluded based on the significance of the activity equals or exceeds the group's total net income; and secondly, if the effective tax rate is equal to or greater than the 15% minimum rate. The article explicitly states that no tax exemptions apply to this tax. Further procedural controls and conditions are deferred to the executive regulations.

Document Type: Tax Law Article
Law: QDMTT Law (Decree-Law no. 157 of 2024)
Article Number: tl-12
Country: 🇰🇼 Kuwait
Location: Chapter 3 - Tax Imposition and Entitlement
Order: 18
Last updated at: 2025-12-19 09:23:03 UTC

Chapter 3 - Tax Imposition and Entitlement [G1]

Article 12 - Tax Calculation

The tax on the taxpayer is calculated by multiplying the tax rate by the taxable income.

The tax will be zero in either of the following two cases:

  1. If the income excluded based on the significance of the activity equals or exceeds the total net income of the taxable entities within a group.

  2. If the effective tax rate is equal to or exceeds (15%).

No tax exemptions apply to this tax.

The executive regulations specify the controls and conditions related to the application of the provisions of this Article.

GTL Notes

[G1]We have corrected the numbering of the Chapter based on the Explanatory Memorandum

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