Article 10 of Kuwait's Decree-Law No. 157 of 2024 establishes the framework for the Substance-Based Income Exclusion (SBIE). It allows a taxpayer to reduce their GloBE income by an amount reflecting their substantial economic activities within Kuwait. This exclusion is calculated as the sum of two components: a carve-out for payroll costs, set between 5% and 9.6% of total salary expenses, and a carve-out for tangible assets, set between 5% and 7.6% of their average book value. The article mandates that detailed controls and conditions for applying this provision will be specified in the executive regulations.