Ministerial Decision No. 55 of 2025 establishes Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 57 provides an elective regime for a Domestic Constituent Entity (DCE) to treat an Investment Entity or Insurance Investment Entity as tax-transparent. This five-year election is conditional upon the owner being subject to a mark-to-market tax system in its jurisdiction on its ownership interest at a rate equal to or exceeding the 15% minimum tax rate. If elected, the standard ETR calculation under Article 56 is disapplied.
CHAPTER 7 - TAX NEUTRALITY AND DISTRIBUTION REGIMES
Article 57 - Election of Tax Transparency for Investment Entities
A DCE may elect to treat an Investment Entity or an Insurance Investment Entity as a Tax Transparent Entity, provided the following two conditions are met:
Continue Reading
Access Full Content
You're viewing a preview of this document. Please log in to unlock the complete content, annotations, and research tools.
Click here to view details of the free plan and the subscriptions we offer.