Article 16 of Decree-Law No. 157 of 2024 provides a temporary zero-tax relief for a taxpayer within a Multinational Entity (MNE) group during its initial phase of international activity. This exemption is subject to specific conditions: the MNE group must have constituent entities in no more than six jurisdictions, and the total net book value of its tangible assets must not exceed EUR 50 million, excluding the jurisdiction with the highest asset value. Additionally, the parent entity must not apply an Income Inclusion Rule to its Kuwaiti holdings. This relief is limited to five tax periods.
Chapter 3 - Tax Imposition and Entitlement
Article 16 - Initial Phase of International Activity
The tax on the taxpayer will be zero during the initial phase of international activity if it is part of a group of multinational entities that meets the following conditions:
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