Kuwait has approved the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports through Decree-Law No. 116 of 2026, published in the Official Gazette on 18 October 2026.
Kuwait has approved the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) through Decree-Law No. 116 of 2026, published in the Official Gazette Kuwait Al-Youm on 18 October 2026.
The agreement aims to strengthen international tax transparency, facilitate the automatic exchange of information between tax authorities and help identify transfer pricing risks and base erosion and profit shifting.
Kuwait has not yet implemented CbC reporting requirements, but their introduction is expected in the near future.
Agreement approval and implementation
Kuwait signed the CbC MCAA in Paris on 22 June 2026. Decree-Law No. 116 of 2026 entered into force on the date of its publication in the Official Gazette.
The agreement provides a legal framework for participating jurisdictions to exchange Country-by-Country Reports automatically each year. Its implementation is intended to improve cooperation between tax authorities and strengthen their ability to assess the tax affairs of multinational enterprise groups operating across multiple jurisdictions.
Scope of information exchange
The agreement enables competent authorities to obtain information about the global allocation of income and taxes paid by multinational enterprise groups, as well as indicators of the locations of their economic activities.
These reports are designed to support tax risk analysis and improve the effectiveness of tax oversight. The information can help authorities identify potential transfer pricing risks and risks relating to base erosion and profit shifting.
Reporting deadlines and procedures
The CbC MCAA establishes requirements covering the information to be exchanged, submission deadlines and electronic transmission methods. Reports must be transmitted using standardised encryption protocols.
The first exchange of reports must take place no later than 18 months after the end of the relevant financial year. Subsequent exchanges must be completed within 15 months of the end of the financial year of the relevant multinational enterprise group.
These provisions establish a common framework for the timely exchange of information among participating jurisdictions.
Confidentiality and use of reports
All exchanged information is subject to confidentiality and data protection rules and may be used only for authorised purposes. These include assessing transfer pricing risks and risks relating to base erosion and profit shifting, alongside economic and statistical analyses where appropriate.
The agreement also clarifies the limitations on using Country-by-Country Reports in transfer pricing assessments. The reports do not constitute conclusive evidence that transfer prices are appropriate or inappropriate and cannot be used as the sole basis for making transfer pricing adjustments. However, they may provide grounds for further enquiries during tax examinations and audits.
Non-Compliance and dispute resolution
The agreement establishes mechanisms for correcting errors and addressing non-compliance. Competent authorities may consult each other to resolve implementation difficulties and address undesirable economic consequences arising from the exchange arrangements.
Information exchange may also be temporarily suspended in cases of serious non-compliance, subject to the conditions and procedures specified in the agreement.
The CbC MCAA comprises nine articles covering definitions, information exchange, deadlines and procedures, cooperation in addressing errors, confidentiality and data protection, consultations, amendments, entry-into-force conditions and the role of the Coordinating Body Secretariat.
