Ministerial Decision No. 55 of 2025 provides the executive framework for Kuwait's Domestic Minimum Top-up Tax (DMTT) regime under Decree-Law No. 157 of 2024. Article 42 establishes the core formula for calculating the Top-up Tax rate applicable to a Multinational Enterprise (MNE) Group. It mandates that for each tax period, the applicable rate is determined by subtracting the MNE Group's jurisdictional Effective Tax Rate (ETR) from the statutory 15% minimum tax rate, a critical step aligned with the OECD's Pillar Two GloBE model.
CHAPTER 5 - EFFECTIVE TAX RATE AND TAX (TOP-UP TAX)
Article 42 - Tax Rate and Tax Calculations
The calculation for the Tax rate for the MNE Group, located in the State shall be computed per Tax Period according to the following formula below:
Tax Rate = Minimum Tax Rate of 15% - ETR
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