Ministerial Decision No. 55 of 2025 governs the imposition of the Top-Up Tax under Kuwait’s DMTT framework. Article 8 mandates that tax is levied on Taxable Entities as defined in Article 4, applied to the taxable income for each Tax Period. Crucially, the regulations state that the total Taxable Income is subject to tax regardless of the specific percentage of Ownership Interests held, directly or indirectly, by the Ultimate Parent Entity (UPE) of the MNE Group.