Ministerial Decision No. 55 of 2025 implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 26 introduces an anti-avoidance rule for intra-group financing arrangements. It mandates the exclusion of financing expenses incurred by a low-tax Constituent Entity (CE) in Kuwait from its GloBE Income or Loss calculation. This applies if the arrangement with a high-tax counterparty within the MNE Group is anticipated to artificially increase the CE's expenses without a commensurate increase in the counterparty's taxable income, safeguarding the domestic tax base.