It has been nearly seven months since Kuwait adopted the Domestic Minimum Top-up Tax (DMTT) Law, and in this short span, we’ve already witnessed significant shifts in how businesses operate across the region. The introduction of this legislation marks a pivotal moment in Kuwait’s tax landscape, aligning the country with global tax reform efforts under the OECD’s Pillar Two framework.
On 29 June 2025, the Ministry of Finance in Kuwait issued Ministerial Order No. 55 of 2025, enacting the Executive Bylaws under Decree Law No. 157 of 2024. These Bylaws establish the operational framework for the DMTT, broadly aligned with the OECD’s GloBE Model Rules, while incorporating Kuwait-specific provisions.
Throughout this guide, our team at KPMG in Kuwait has carefully reviewed the full text of the Executive Bylaws and translated them into an easy-to-understand resource. We’ve broken down the content into key focus areas such as taxability, permanent establishment (PE), covered taxes, corporate restructuring, safe harbours, transfer pricing, and the way forward—to help you navigate the complexities and assess the implications for your organization.
This guidebook is intended to support your understanding of the DMTT framework and its implications. As developments unfold, we remain committed to providing timely insights and technical clarity to help you navigate the changes with confidence.
