Ministerial Decision No. 55 of 2025 implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 53 provides a specific definition for a Joint Venture (JV) for GloBE purposes. A JV is an entity whose financials are equity-accounted in the UPE's statements, with the UPE holding at least 50% ownership. The Article explicitly lists exclusions, such as Excluded Entities and UPEs themselves. Crucially, it mandates that a JV and its subsidiaries be treated as a separate MNE Group for calculating Top-Up Tax, requiring a distinct Effective Tax Rate (ETR) computation.
CHAPTER 6 - CORPORATE RESTRUCTURINGS AND HOLDING STRUCTURES