Ministerial Decision No. 55 of 2025, implementing Kuwait's DMTT framework under Decree-Law No. 157 of 2024, introduces safe harbour provisions in this Article. Article 60 stipulates that the Top-Up Tax for an MNE Group's operations in Kuwait can be deemed zero if it satisfies one of three tests using a simplified calculation method. These are the Routine Profit Test (comparing GloBE Income to SBIE), the De Minimis Test (revenue below EUR 10M, income below EUR 1M), or the Simplified ETR Test (ETR at or above 15%), aligning with OECD Pillar Two principles.
CHAPTER 8 - SAFE HARBOR AND INITIAL PHASE OF INTERNATIONAL ACTIVITY
Article 60 - Safe Harbor by Simplified Calculation Method
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