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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 69 provides the legal definition of 'Related Persons' for transfer pricing adjustments under the GloBE rules. It specifies that a relationship exists based on common control, significant influence, or where one person holds 50% or more of the ownership interests in another. This definition explicitly covers connections between natural persons and entities, between two entities where one controls the other, or two entities under the common control of a third person.

CHAPTER 10 - TRANSFER PRICING FOR RELATED PERSONS

Article 69 - Related Persons

Persons are considered related if there is a common connection between them or with another Person, if one Person has significant influence or control over another, or if two or more Persons are under common control, including

A natural person and an entity, if the natural person, alone or together with its Related Persons, directly or indirectly owns 50% or more of the Ownership Interests of the entity or controls the entity.
Two Entities, where one of them, either alone or with related Persons, owns directly or indirectly, 50% or more of the Ownership Interest in the other Entity, or controls the other Entity.
Two Entities under common control by a Person, alone or with related Persons, who owns, directly or indirectly, 50% Ownership Interest or more, in both Entities.