Ministerial Decision No. 55 of 2025 details Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 63 establishes the rules for the Transitional Country-by-Country Reporting Safe Harbour (TCSH). It specifies that Joint Ventures are treated as separate MNE Groups and sets conditions for Flow-through Ultimate Parent Entities. The article provides special rules for Investment Entities, including a separate ETR calculation, and mandates the exclusion of net unrealised fair value losses exceeding EUR 50 million. Stateless entities and certain multi-parented groups are explicitly excluded from this safe harbour.
CHAPTER 8 - SAFE HARBOR AND INITIAL PHASE OF INTERNATIONAL ACTIVITY
Article 63 - Treatment of Certain Entities and Groups under the Transitional Safe Harbor for Country-by-Country Reporting (TCSH)
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