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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 74 specifies the mandatory transfer pricing documentation for taxable entities engaging in transactions with related persons. It mandates the preparation and retention of a Master File and a Local File, which must be submitted to the Tax Administration within 30 days of a request. Additionally, an audited disclosure form detailing the value, nature, and pricing methodology of such transactions must be submitted with the annual tax return.

CHAPTER 10 - TRANSFER PRICING FOR RELATED PERSONS

Article 74 - Transfer Pricing Documentation

The taxable entity must prepare and retain the following documentation:

Master File and Local File, to be submitted within 30 days of a request from the Tax Administration.
Disclosure form for transactions with related Persons, audited by an audit firm approved by the Ministry, to be submitted with the Tax Return. This form particularly must include:
1. Value and nature of transactions with related persons.
2. Method used to price these transactions.
3. Any additional information required by the Tax Administration.