Kuwait

Pillar Two developments in Kuwait

Domestic Minimum Top-up Tax (DMTT)

In December 2024, the Government of Kuwait released its DMTT Law which marks a significant milestone in the evolution of Kuwait’s tax framework. The DMTT Law is considered partially enacted since the Executive Bylaws are yet to be issued, i.e. to be issued by a decision of the Minister within six months from the date of publication of the Law in the Official Gazette (i.e. 30 June 2025). The Top-up Tax takes the form of a Domestic Minimum Top-up Tax (“DMTT”), and will apply to large multinational enterprises (MNEs) that are in scope of Pillar Two effective from 1 January 2025. The tax will be imposed in cases where the MNE’s ETR in Kuwait is below 15%.