Ministerial Decision No. 55 of 2025 implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 46 provides special rules for calculating the Substance-Based Income Exclusion (SBIE). It specifies that the Eligible Payroll Costs and Eligible Tangible Assets of a Permanent Establishment (PE) are attributed to the PE's jurisdiction, not the Main Entity. The Article mandates proportional exclusion of these assets if the PE's income is excluded. It also requires separate SBIE calculations for entities like JVs and Investment Entities, and provides allocation rules for Flow-through Entities.