Ministerial Decision No. 55 of 2025 implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 32 establishes the rules for allocating the Financial Accounting Net Income or Loss (FANIL) of a Flow-through Entity. It mandates a clear hierarchy, first allocating income to any Permanent Establishment (PE) as per Article 31. Any remaining FANIL is then allocated to Constituent Entity-owners if the entity is tax-transparent, or to the entity itself if it is an Ultimate Parent Entity or Reverse Hybrid Entity.