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May 15, 2026

Ministerial Decision No. 55 of 2025 establishes Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 35 outlines the mandatory additions to a Constituent Entity's covered taxes for the tax period, a critical step in calculating the GloBE Effective Tax Rate. The additions comprise four specific items: covered taxes expensed in financial accounts, the Deferred Tax Asset amount arising from GloBE Losses, taxes paid regarding a previously uncertain tax position, and balances related to Qualified Refundable Tax Credits (QRTC) or Marketable Transferable Tax Credits.

CHAPTER 4 - CALCULATION OF ADJUSTED COVERED TAXES

Article 35 - Additions to Covered Taxes

Additions to the covered taxes of the CE for the Tax Period are calculated as the sum of the following items:

Any amount of Covered Taxes accrued as an expense in the profit before taxation in the financial accounts;
Any amount of DTA resulting from GloBE Losses used in accordance with paragraph 3 of Article 39 of these ERs;
Any amount of Covered Taxes paid during the Tax Period related to an uncertain tax position, if that amount was treated in a previous Tax Period as a Reduction in Covered Taxes under clause (4) of paragraph 1 of Article 36 of these ERs; and
Any balance or refund related to a QRTC or a Marketable and Transferable Tax Credit, recorded as a reduction in current tax expense.