Ministerial Decision No. 55 of 2025 operationalises Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 37 establishes precise rules for allocating Covered Taxes between Constituent Entities (CEs). It explicitly prohibits certain cross-border allocations, including taxes from a foreign Main Entity to a Kuwaiti Permanent Establishment (PE) or from a foreign CE-Owner under a CFC Tax Regime to a local CE. The article provides specific guidance for Tax-Transparent and Hybrid Entities, and caps the allocable tax on passive income, ensuring tax attribution aligns with GloBE principles.