Ministerial Decision No. 55 of 2025 implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 55 provides tax neutrality rules for an Ultimate Parent Entity (UPE) that is a Flow-through Entity. It permits the reduction of the UPE's GloBE Income attributable to its owners if they are subject to a tax rate of at least 15%. The reduction also applies if the owner is a natural person, Governmental Entity, or other specified entity holding 5% or less ownership. GloBE losses and Covered Taxes are reduced proportionally.