Ministerial Decision No. 55 of 2025, which implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024, establishes the Substance-based Income Exclusion (SBIE) in this Article. This provision allows Multinational Enterprise (MNE) Groups to reduce their Net GloBE Income by an amount reflecting substantive economic activities, thereby lowering the taxable excess profit subject to the Top-up Tax. The SBIE is calculated from a prescribed percentage of Eligible Payroll Costs and Eligible Tangible Assets for Constituent Entities in Kuwait, aligning with OECD Pillar Two GloBE Rules.