Ministerial Decision No. 55 of 2025 establishes Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 74 specifies the mandatory transfer pricing documentation for taxable entities engaging in transactions with related persons. It mandates the preparation and retention of a Master File and a Local File, which must be submitted to the Tax Administration within 30 days of a request. Additionally, an audited disclosure form detailing the value, nature, and pricing methodology of such transactions must be submitted with the annual tax return.
CHAPTER 10 - TRANSFER PRICING FOR RELATED PERSONS
Article 74 - Transfer Pricing Documentation
The taxable entity must prepare and retain the following documentation:
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