The following Entities are subject to Tax (Top-Up Tax):
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July 23, 2026
Ministerial Decision No. 55 of 2025 implements Kuwait's Domestic Minimum Top-up Tax (DMTT) framework under Decree-Law No. 157 of 2024. Article 4 defines the entities subject to the Top-up Tax. It specifies that any Constituent Entity (CE) in Kuwait, part of a Multinational Enterprise (MNE) Group meeting the revenue threshold, is liable. This scope extends to Investment Entities, Joint Ventures (JVs) under specific ownership or revenue conditions, and stateless entities with local activities. The article explicitly references Article 5, clarifying that designated Excluded Entities are exempt from this tax.
CHAPTER 2 - TAXABLE AND EXCLUDED ENTITIES
Article 4 - Taxable Entities
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