Recent Pillar Two Developments in Kuwait​

In brief ​

On June 30, 2025, the Ministry of Finance (MoF) published the “Executive Regulations” for the Domestic Minimum Top-Up Tax (DMTT) for Multinational Enterprises (MNEs) under Ministerial Resolution No. (55) of 2025. ​​

The Executive Regulations supplement the DMTT Law (Decree by Law No. 157) released on 30 December 2024. As a general overview, the DMTT Law applies a 15% to Kuwait profits of MNEs with global consolidated revenues of at least EUR 750 million in at least two of the previous four fiscal years. This includes MNEs headquartered in Kuwait as well as foreign MNEs with operations in Kuwait. However, the DMTT Law does not apply to local businesses with operations limited to Kuwait or that do not meet the revenue test. The DMTT Law is effective from 1 January 2025. ​​

As anticipated, the Executive Regulations are largely in line with the GloBE Model Rules. For entities already in-scope, the DMTT Law requires that within a period of nine months from the law’s effective date (i.e. until 30 September 2025), in-scope entities must register with the tax administration without incurring administrative penalties. Further, for entities not in-scope on 1 January 2025, the DMTT Law alongside Article 75 of the Executive Regulations require such entities to register within 120 days from the date they become subject to tax (DMTT). It is therefore important to assess your group’s specific tax liability commencement date to ensure timely compliance, even if you qualify for any Safe Harbours or exclusions. ​​

For further details on the immediate steps you need to take to meet your Kuwait DMTT compliance and registration obligations, see our section below titled “Must-Do Immediate Next Steps”.​