Ministerial Decision No. 55 of 2025, implementing Kuwait's DMTT framework under Decree-Law No. 157 of 2024, outlines rules for allocating income between a Main Entity and a Permanent Establishment (PE) in this Article. It mandates calculating the PE's Financial Accounting Net Income or Loss (FANIL) based on its separate financial accounts, subject to specific adjustments aligned with applicable tax treaties or the OECD Model Tax Convention. The Article clarifies that a PE's FANIL is generally excluded from the Main Entity's GloBE income, providing a key exception for treating PE losses as an expense for the Main Entity, with a subsequent recapture provision.