This Rule defines and outlines the tax treatment of foreign management fees paid to an Incorporated Body for management activities under contract. It specifies that for an Incorporated Body participating in a Kuwaiti company, such fees are accepted as costs for the local company but added to the net profit of the foreign body. When an Incorporated Body completely manages a Kuwaiti company, the fees are considered earned revenues. The Rule further clarifies that under deemed profit inspection, these fees are treated as net full profit. Exceptional cases require separate consultation with the Tax Department.