Ministerial Decision No. 55 of 2025 establishes Kuwait's DMTT framework under Decree-Law No. 157 of 2024, outlining specific compliance obligations. Article 94 details the extensive record-keeping requirements for taxpayers, mandating the retention of all books, records, and information necessary for preparing financial statements, determining taxable income, and satisfying Pillar Two obligations. This includes financial accounts, ledgers, transfer pricing documentation, and supporting invoices. A crucial provision is the mandatory retention period, which is set at a minimum of 10 years from the end of the relevant tax period.
CHAPTER 14 - BOOKS AND RECORDS
Article 94 - Retention of Books and Records
The Taxpayer must retain books, records, documents, and information required by the nature of the Taxpayer’s activity to prepare FS, determine taxable income, and meet the requirements of Pillar Two. These include:
Balance sheet
Profit and loss accounts
Cash flow statements
Statement of equity
General Ledger
Fixed asset register
Payroll records
Liability records
Inventory
Transfer pricing documentation
Stock register
Supporting documents for entries in books, records, and Tax Returns, such as:
Invoices, contracts, licenses, and correspondence;
Documents showing the simplified calculation methods used by the Taxpayer under the Law and its ERs.
Any other books, records, or documents specified by the Tax Administration.
All records must be retained for a minimum of 10 years from the end of the Tax Period to which the records, documents, and information relates.
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