Beta Version
Website Last updated:
July 23, 2026
Ministerial Decision No. 55 of 2025 establishes Kuwait's Domestic Minimum Top-up Tax (DMTT) framework under Decree-Law No. 157 of 2024. Article 6 specifically defines the treatment of a Sovereign Wealth Fund (SWF). It clarifies that an SWF is not considered an Ultimate Parent Entity (UPE) or a member of an MNE Group, and its revenues are excluded when calculating the consolidated revenue threshold. However, an entity directly controlled by an SWF can qualify as a UPE if it controls other entities or operates as a Main Entity with foreign Permanent Establishments.
CHAPTER 2 - TAXABLE AND EXCLUDED ENTITIES
Article 6 - Sovereign Wealth Fund (SWF)
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.