Ministerial Decision No. 55 of 2025 establishes Kuwait's DMTT framework under the DMTT Law. Article 50 provides specific rules for applying the EUR 750 million consolidated revenue threshold to Multinational Enterprise (MNE) Groups undergoing mergers or demergers. For mergers, the threshold is tested by combining the historical revenues of the merging groups from the preceding four tax periods. For demergers, a newly formed 'Separate Group' must meet the threshold in the demerger year and in at least two of the subsequent three tax periods. The Article defines 'merger' and 'demerger' for these purposes.
CHAPTER 6 - CORPORATE RESTRUCTURINGS AND HOLDING STRUCTURES
Article 50 - Application of the Consolidated Revenue Threshold to Group Mergers and Demergers
The Consolidated Revenue Threshold to group mergers and demergers is determined according to the following provisions:
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