Ministerial Decision No. 55 of 2025 establishes Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 64 outlines the safe harbour for an MNE Group in its Initial Phase of International Activity (IPIA), setting the Top-Up Tax to zero. To qualify, the MNE Group must have constituent entities in no more than six jurisdictions and the total net book value of tangible assets must not exceed EUR 50 million, excluding the jurisdiction with the highest asset value. This transitional relief is available for five tax periods.