Ministry of Finance - Tax Department - 2013 [Executive Rules & Instructions]
Executive Rule No. 45 Concerning the Foreign Management Fees
Article No. 3 of the Executive Regulations
First: Foreign management fees are the amounts paid to each Incorporated Body that exercises management activities in return of fees under contract stipulations.
Second: As for Incorporated Body participating in a Kuwaiti company, these fees shall be accepted as costs for the company as a whole and at the same time shall be added to the full net profit of the Incorporated Body.
Third: For the fees acquired by the Incorporated Body in return for complete management of a Kuwaiti company, the Incorporated Body shall be charged for these fees as earned revenues.
Fourth: In case of deemed profit inspection, these fees shall be treated as net full profit since such fees are considered as revenues without expenses in return.
Fifth: Special and exceptional cases relating to foreign management fees shall be separately treated after consulting the Tax Department in this regard.