Ministerial Decision No. 55 of 2025 enforces compliance with the Arm’s Length Principle for transactions between Related Persons. Article 73 explicitly empowers the Tax Administration to adjust Transfer Prices if they fail to adhere to this principle. Such adjustments will be calculated using the approved methods outlined in Article 72. This provision ensures the Tax Administration can effectively monitor MNE Group compliance through both targeted deep-dives and broader systematic checks.
Document Type: ERS - Executive Regulations Law: QDMTT Law (Decree-Law no. 157 of 2024) Decision Number: executive-regulations-55-article-73 Year: 2025 Country: 🇰🇼 Kuwait Official Name: Article 73 - Application of the Arm’s Length Principle
Last updated at: 2026-02-23 12:13:40 UTC
CHAPTER 10 - TRANSFER PRICING FOR RELATED PERSONS
Article 73 - Application of the Arm’s Length Principle
Related Persons must adhere to the Arm’s Length Principle, or else the Tax Administration has the right to adjust the Transfer Price based on the methods listed in Article 72 of these ERs.