Article 4 of Kuwait's QDMTT law specifies entities excluded from the top-up tax, regardless of their Kuwaiti or non-Kuwaiti status. The list includes Governmental Entities, Non-Profit Organizations, International Organizations, and Pension Funds. Additionally, Investment Funds and Real Estate Investment Vehicles acting as Ultimate Parent Entities (UPEs) are exempt. The exclusion extends to entities, excluding pension service entities, that are at least 95% owned by these exempt bodies and exist to hold assets, or at least 85% owned and derive all income from excluded dividends or equity gains. The law notes that executive regulations may further define application controls.