GTL Summary:

Ministerial Decision No. 55 of 2025 implements Kuwait's Domestic Minimum Top-up Tax (DMTT) framework under Decree-Law No. 157 of 2024. Article 4 defines the entities subject to the Top-up Tax. It specifies that any Constituent Entity (CE) in Kuwait, part of a Multinational Enterprise (MNE) Group meeting the revenue threshold, is liable. This scope extends to Investment Entities, Joint Ventures (JVs) under specific ownership or revenue conditions, and stateless entities with local activities. The article explicitly references Article 5, clarifying that designated Excluded Entities are exempt from this tax.

Document Type: ERS - Executive Regulations
Law: QDMTT Law (Decree-Law no. 157 of 2024)
Decision Number: executive-regulations-55-article-4
Year: 2025
Country: 🇰🇼 Kuwait
Official Name: Article 4 - Taxable Entities
Last updated at: 2026-02-23 12:13:40 UTC

CHAPTER 2 - TAXABLE AND EXCLUDED ENTITIES

Article 4 - Taxable Entities

The following Entities are subject to Tax (Top-Up Tax):

  1. Any CE located in the State, that is a member of an MNE Group meeting the Revenue Threshold, including CEs that are members of a minority-owned sub-group. An Investment Entity located in the State that is part of an MNE Group meeting the Revenue Threshold shall not be considered an Excluded Entity.

  2. Any JV or JV Subsidiary located in the State and member of an MNE group, in either of the following cases:

    1. If the JV has a share of (50%) or more owned by an UPE of an MNE Group whose revenues from outside the JV that meets the Revenue Threshold.

    2. If the total revenues of the JV and its subsidiaries have reached or exceeded the Revenue Threshold.

  3. Any Stateless Entity that conducts activities in the State and is a member of an MNE Group that meets the Revenue Threshold.

    Entities that are considered Excluded Entities under Article 5 of these ERs are not subject to the Tax.

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