Ministerial Decision No. 55 of 2025 operationalises Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 5 specifies the categories of Excluded Entities exempt from the Top-up Tax, aligning with OECD Pillar Two standards. These include Government Entities, Non-Profit Organizations, International Organizations, Pension Funds, and specific Investment or Real Estate Funds that are Ultimate Parent Entities (UPEs). The article provides detailed qualification criteria, including ownership thresholds (e.g., 95% or 85%) for subsidiary entities, and sets forth strict definitions for 'Governmental Entity' and 'Non-Profit Organization'.