GTL Summary:

Ministerial Decision No. 55 of 2025 establishes Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 28 provides specific rules for calculating the GloBE Income or Loss of a Constituent Entity that is an insurance company. It mandates adjustments to the Net Financial Accounting Net Income or Loss (FANIL), requiring the exclusion of taxes charged to policyholders for their returns and the inclusion of certain policyholder returns not otherwise reflected. This ensures the tax base aligns with the OECD's Pillar Two GloBE Model Rules for the insurance sector.

Document Type: ERS - Executive Regulations
Law: QDMTT Law (Decree-Law no. 157 of 2024)
Decision Number: executive-regulations-55-article-28
Year: 2025
Country: 🇰🇼 Kuwait
Official Name: Article 28 - Exclusion of Certain Insurance Company Income
Last updated at: 2026-02-23 12:13:40 UTC

CHAPTER 3 - GLOBE INCOME OR LOSS

Article 28 - Exclusion of Certain Insurance Company Income

To determine GloBE income or Loss, a CE that is an Insurance Company must adjust its Net FANIL as follows:

  1. Amounts charged to policyholders for taxes paid by the Insurance Company in respect to policyholder returns shall be excluded when calculating GloBE Income or Loss.

  2. Any returns due to policyholders that are not reflected in the FANIL must be included in the GloBE Income or Loss to the extent the corresponding increase or decrease in liability to policyholders is reflected in the net FANIL.

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