The Ministry of Finance (MoF) has issued Circular No. 1 of 2026 (“Circular”), setting out a mechanism for an optional advance tax payment for taxpayers which fall under the Kuwait Domestic Minimum Top-up Tax (“DMTT”), based on a provisional DMTT return.
On 31 December 2024, the Government of Kuwait published Decree Law No. 157 of 2024 (“DMTT Law”) in the Official Gazette. This legislation introduced the DMTT effective for periods commencing on or after 1 January 2025, establishing a minimum tax rate of 15% applicable to multinational enterprise (“MNE”) groups with annual revenues exceeding EUR 750 Million, in alignment with the OECD’s BEPS Pillar II framework.
Pursuant to the DMTT Law, the Executive Bylaws were issued in June 2025 (collectively referred to as “Kuwait DMTT legislation” or “Kuwait DMTT regime”). The Executive Rules are still awaited and are expected to provide detailed procedural guidance and mechanisms for treatment of the DMTT Law and its Executive Bylaws.
The statutory deadline to submit the DMTT return is 15 months after the year end. For example, where a taxpayer had a year end of 31 December 2025, the deadline to file the DMTT return is 31 March 2027.
The Circular allows taxpayers the option to make an advance payment of tax through the submission of a Provisional Tax Return. It should be noted that this process is voluntary and does not constitute a mandatory requirement for taxpayers falling under the scope of the DMTT.
