This memorandum outlines Kuwait's adoption of the OECD's Pillar Two international tax reform to address profit shifting by Multinational Entities (MNEs). Having joined the BEPS framework, Kuwait plans to implement a global minimum top-up tax by 1 January 2025 to prevent significant tax revenue leakage to jurisdictions that have already adopted these rules. The draft decree-law contains five articles covering the effective date, registration, legal precedence, and ministerial powers. The accompanying MNE tax law consists of 41 articles across 8 chapters, detailing definitions, scope, tax calculation, taxpayer obligations, auditing procedures, penalties, and tax evasion.
Explanatory Memorandum
Draft Law No. (157) of 2024
Issuing the Tax Law on Group of Multinational Entities (MNEs)
The Organization for Economic Co-operation and Development (OECD) launched an international tax reform initiative under the name "Pillar Two," which specifically targets the practices of multinational entities operating in multiple countries and shifting profits to low-tax states.
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