GTL Summary:

Ministerial Decision No. 55 of 2025 establishes Kuwait's Domestic Minimum Top-up Tax (DMTT) framework under Decree-Law No. 157 of 2024. Article 6 specifically defines the treatment of a Sovereign Wealth Fund (SWF). It clarifies that an SWF is not considered an Ultimate Parent Entity (UPE) or a member of an MNE Group, and its revenues are excluded when calculating the consolidated revenue threshold. However, an entity directly controlled by an SWF can qualify as a UPE if it controls other entities or operates as a Main Entity with foreign Permanent Establishments.

Document Type: ERS - Executive Regulations
Law: QDMTT Law (Decree-Law no. 157 of 2024)
Decision Number: executive-regulations-55-article-6
Year: 2025
Country: 🇰🇼 Kuwait
Official Name: Article 6 - Sovereign Wealth Fund ( SWF )
Last updated at: 2026-02-23 12:13:40 UTC

CHAPTER 2 - TAXABLE AND EXCLUDED ENTITIES

Article 6 - Sovereign Wealth Fund (SWF)

An SWF is not considered a UPE or a member of an MNE Group, and its revenues are not taken into account when calculating the Revenue Threshold for Entities in which it holds a Controlling Interest.

If an SWF directly owns a Controlling Interest in an Entity, that Entity shall be considered a UPE of an MNE Group if one of the following conditions are met:

  1. It owns (directly or indirectly) a Controlling Interest in another Entity.

  2. It is a Main Entity located in one Jurisdiction with one or more PEs located in other jurisdictions, provided that the Main Entity is not part of another Group.

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