Kuwait’s Ministry of Finance issued Executive Regulations under Ministerial Resolution No. (55) of 2025 on 29 June 2025, detailing the implementation of the Domestic Minimum Top-Up Tax (DMTT) introduced by Decree-Law No. (157) of 2024.
This announcement was made by the Ministry of Finance on the same day.
The DMTT took effect on 1 January 2025. It applies a 15% minimum tax on in-scope multinational enterprise (MNE) groups.
The Executive Regulations outline key compliance requirements, including mandatory tax registration, return submission procedures, tax calculation rules, safe harbour provisions, and administrative penalties for non-compliance. The rules also clarify the interaction between Kuwait’s DMTT and the OECD’s Qualified Domestic Minimum Top-Up Tax under Pillar Two.
In addition to DMTT provisions, the regulations introduce transfer pricing requirements aligned with OECD guidelines. These include the obligation to prepare and submit a master file and local file within 30 days of request and an audited transfer pricing disclosure form to be filed alongside the tax declaration. Related parties are defined as those with at least 50% direct or indirect control, or common control by a third party.
The Ministry stated that the new rules aim to enhance transparency, ensure tax equity, and support Kuwait’s fiscal sustainability goals in line with “Kuwait Vision 2035.” Estimated annual revenues from the DMTT are projected at approximately KWD 250 million. The Ministry plans to hold awareness workshops to assist stakeholders with understanding and implementing the regulations.
Earlier, Kuwait’s Ministry of Finance announced on X that a supplementary domestic minimum top-up tax (DMTT) for large multinational enterprises (MNEs) was introduced through Decree No. (157) of 2024 on 30 December 2024.
