GTL Summary:

Ministerial Decision No. 55 of 2025 governs the imposition of the Top-Up Tax under Kuwait’s DMTT framework. Article 8 mandates that tax is levied on Taxable Entities as defined in Article 4, applied to the taxable income for each Tax Period. Crucially, the regulations state that the total Taxable Income is subject to tax regardless of the specific percentage of Ownership Interests held, directly or indirectly, by the Ultimate Parent Entity (UPE) of the MNE Group.

Document Type: ERS - Executive Regulations
Law: QDMTT Law (Decree-Law no. 157 of 2024)
Decision Number: executive-regulations-55-article-8
Year: 2025
Country: 🇰🇼 Kuwait
Official Name: Article 8 - Imposition and Accrual of Tax (Top-up Tax)
Last updated at: 2026-02-23 12:13:40 UTC

CHAPTER 2 - TAXABLE AND EXCLUDED ENTITIES

Article 8 - Imposition and Accrual of Tax (Top-up Tax)

The Tax shall be levied on the Taxable Entities defined in Article 4 of these ERs, on the taxable income for each Tax Period.

For the purpose of imposing the Tax, the total Taxable Income is taken into account regardless of the percentage of the Ownership Interests in the Taxable Entity held, directly or indirectly, by the UPE of the MNE Group.

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