Control, as referred to in the previous Article, exists in the ability of any Person, alone or with related Persons, to directly or indirectly exercise an effective influence on the decisions or operations of another Person. This includes:
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July 23, 2026
Ministerial Decision No. 55 of 2025, implementing Kuwait's DMTT Law, addresses transfer pricing for related persons in Chapter 10. Article 70 specifically defines the concept of 'Control'. Control is established when a person can exercise effective influence over another, evidenced by holding 50% or more of voting rights, board seats, capital, or profits. It also includes managing operations, providing 50% or more of loans (excluding financial institutions), or providing 25% or more of guarantees. This definition is crucial for identifying related-party transactions under the new tax framework.
CHAPTER 10 - TRANSFER PRICING FOR RELATED PERSONS
Article 70 - Control
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