GTL Summary:

Ministerial Decision No. 55 of 2025, implementing Kuwait's DMTT framework, provides for tax settlement procedures in Article 107. This provision authorises the Tax Administration to agree with a taxpayer on a final Top-Up Tax amount, without prejudice to other statutory fines and penalties. The settlement must be documented in a formal memorandum, which forms the basis for an amended, final assessment. The Article also defines the procedural steps for settlements reached during a formal grievance or a court appeal, requiring notification to the relevant bodies before a final judgment.

Document Type: ERS - Executive Regulations
Law: QDMTT Law (Decree-Law no. 157 of 2024)
Decision Number: executive-regulations-55-article-107
Year: 2025
Country: 🇰🇼 Kuwait
Official Name: Article 107 - Tax Settlement Agreement
Last updated at: 2026-02-23 12:13:40 UTC

CHAPTER 16 - OBJECTIONS, GRIEVANCES, AND APPEALS

Article 107 - Tax Settlement Agreement

Without prejudice to the fines and penalties stipulated by the Law, the Tax Administration may agree with the Taxpayer on a settlement regarding the Tax Due in accordance with the following conditions and controls:

  1. A memorandum must be prepared proving what the parties have agreed upon regarding the amount of the Tax (Top-Up Tax) and the basis of its calculation.

  2. The Tax Administration will issue an amended assessment in accordance with the agreement, and the Tax stated in the amended assessment will be considered final, which the Taxpayer must pay.

  3. If the agreement is reached during the grievance, the Tax Administration must notify the TGC of what has been agreed upon, along with a memorandum of settlement.

  4. It is a condition while agreeing on a settlement during the appeal before the court that no final judgment be issued, and the memorandum of settlement must be submitted to the competent court.

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