Ministerial Decision No. 55 of 2025 establishes Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 71 specifies the legal criteria for determining comparability in transactions between related persons, a fundamental aspect of transfer pricing compliance for MNE Groups. It mandates a comprehensive analysis based on six key factors: contractual terms, transaction characteristics, economic circumstances, the functional profile (activities, assets, risks), business strategies, and any other conditions set by the Tax Administration. This ensures adherence to the arm's length principle, aligning with OECD transfer pricing guidelines.