Article 3 of Decree-Law No. 157 of 2024 specifies the entities subject to the new tax. This includes any entity in Kuwait that is part of a multinational enterprise (MNE) group, whether it is an ultimate parent entity (UPE) or a participating entity. The scope also extends to joint ventures (JVs) and their subsidiaries in Kuwait if the JV is at least 50% owned by a UPE of an MNE group meeting the revenue threshold, or if the JV group itself meets this threshold. Additionally, stateless entities conducting business in Kuwait are deemed taxable. Executive regulations are expected to provide further controls and conditions.
Chapter 2 - Taxable and Excluded Entities
Article 3 - Taxable Entities
The following entities shall subject to tax:
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