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Under Ministerial Decision No. 55 of 2025, which provides the executive regulations for Kuwait's DMTT Law, Article 12 specifies the treatment of dividends for calculating GloBE Income or Loss. It establishes the default rule of excluding dividends and distributions from the Financial Accounting Net Income or Loss (FANIL). However, this exclusion is subject to conditions related to Short-Term Portfolio Shareholdings. A dividend qualifies for exclusion if the MNE Group holds at least a 10% ownership interest or if the interest has been held for 12 months. The Article also introduces a five-year election to include all portfolio dividends in GloBE income.
CHAPTER 3 - GLOBE INCOME OR LOSS
Article 12 - Excluded Dividends
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