Article 15 establishes a Transitional Country-by-Country Report (CbCR) Safe Harbor, which reduces the top-up tax to zero for tax periods starting on or before 31 December 2026. This relief applies if an MNE Group meets one of three tests in Kuwait: the de minimis test (revenue < €10m and income < €1m), the effective tax rate test (ETR ≥16% for 2025, ≥17% for 2026), or the routine profits test where profit is below the substance-based income exclusion defined in Article 10. The provision excludes stateless entities and certain MNEs. Further controls will be defined by executive regulations.