Article 5 establishes the criteria for determining an entity's location for the purposes of Kuwait's Qualified Domestic Minimum Top-Up Tax (QDMTT). An entity is located in a state if it is a non-pass-through entity and a tax resident there. A pass-through entity is located in a state if it is the Ultimate Parent Entity (UPE) of a multinational group and was established there. A permanent establishment is also considered located in a state if it maintains a place of business, as defined under Article 2. The article clarifies that pass-through entities not meeting the UPE criteria and certain permanent establishments are treated as stateless.