Ministerial Decision No. 55 of 2025 implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 47 defines 'Additional Current Top-Up Tax' as the incremental tax arising from adjustments to Covered Taxes or Net GloBE Income from a prior period, which necessitates an Effective Tax Rate (ETR) recalculation. This provision outlines the procedures for this recalculation, stipulating that any increase in tax is recognised in the current period. It also specifies the formula for allocating this additional tax among Constituent Entities with negative Adjusted Covered Taxes.
CHAPTER 5 - EFFECTIVE TAX RATE AND TAX (TOP-UP TAX)
Article 47 - Additional Current Tax (Top-up Tax) Amount
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