Ministerial Decision No. 55 of 2025 implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 41 provides the mandatory formula for calculating the jurisdictional Effective Tax Rate (ETR) for a Multinational Enterprise (MNE) Group. This rate, determined for each Tax Period, is calculated by dividing the total Adjusted Covered Taxes of all Constituent Entities in Kuwait by their aggregated Net GloBE Income. This ETR calculation is a foundational step aligned with the OECD GloBE Model Rules for determining if a Top-up Tax liability exists.
CHAPTER 5 - EFFECTIVE TAX RATE AND TAX (TOP-UP TAX)
Article 41 - Determination of the Effective Tax Rate (ETR)
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