Ministerial Decision No. 55 of 2025, implementing Kuwait's DMTT framework under Decree-Law No. 157 of 2024, addresses complex MNE structures. Article 54 defines when an MNE Group is considered to have multiple Ultimate Parent Entities (UPEs), specifically through 'Stapled Structures' or 'Dual-List Arrangements'. It mandates that such formations be treated as a single MNE Group for DMTT compliance. The Article provides precise criteria for both arrangement types, focusing on combined ownership, financial consolidation, and operational management, and requires a Designated Constituent Entity to file a consolidated tax return.