GTL Summary:

Ministerial Decision No. 55 of 2025 implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 11 mandates specific adjustments to a Constituent Entity's Financial Accounting Net Income or Loss (FANIL) to compute its GloBE Income or Loss. It requires adding back certain net tax expenses, including all accrued Covered Taxes, Qualified Domestic Minimum Top-up Tax (QDMTT), taxes under the GloBE Rules, and any Deferred Tax Asset attributable to a current-year loss. This ensures that such tax expenses do not reduce the GloBE tax base.

Document Type: ERS - Executive Regulations
Law: QDMTT Law (Decree-Law no. 157 of 2024)
Decision Number: executive-regulations-55-article-11
Year: 2025
Country: 🇰🇼 Kuwait
Official Name: Article 11 - Net Tax Expenses
Last updated at: 2026-02-23 12:13:40 UTC

CHAPTER 3 - GLOBE INCOME OR LOSS

Article 11 - Net Tax Expenses

The FANIL for each CE is adjusted by the amount of net tax expense to determine GloBE Income or Loss, which includes all of the following:

  1. Any Covered Taxes accrued as an expense and any current and deferred Covered Taxes included in the income tax expense, including Covered Taxes on income that is excluded from GloBE Income or Loss computation.

  2. Any DTA attributable to a loss for the Tax Period.

  3. Any QDMTT accrued as an expense.

  4. Any taxes arising under the GloBE Rules treated as an expense.

  5. Any Disqualified Refundable Imputation Tax accrued as an expense. To apply clause (1) of the preceding paragraph, the following shall apply:

    1. Covered Taxes that were deducted in the computation of FANIL, whether accounted for as an above-the-line expense (before the operational result) or as a below-the-line income tax (after the operational result), must be added back to determine the GloBE Income or Loss.

    2. Covered Taxes attributable to income that is excluded from the computation of GloBE Income or Loss must also be added back to FANIL to prevent the tax attributable to the excluded income from being allowed as a deduction in the computation of the GloBE Income or Loss.

Fast-loading version for search engines - Click here for the interactive version