Ministerial Decision No. 55 of 2025 establishes Kuwait's DMTT framework, with Article 65 detailing the Tax Administration's authority over GloBE Safe Harbor applications. The Administration is entitled to review data and may object to a taxpayer's safe harbor election within 36 months of receiving the Tax Return. The article outlines a formal challenge process, requiring the Administration to provide material facts supporting its objection. The taxpayer is then granted a six-month period to prove their eligibility, failing which the safe harbor will be deemed inapplicable.
CHAPTER 8 - SAFE HARBOR AND INITIAL PHASE OF INTERNATIONAL ACTIVITY
Article 65 - Application of Safe Harbor Rules
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