Ministerial Decision No. 55 of 2025 implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 115 provides specific transitional rules for Multinational Enterprise (MNE) Groups regarding tax attributes. It mandates that all Deferred Tax Assets (DTAs) and Deferred Tax Liabilities (DTLs) of Constituent Entities in the State must be taken into account when determining the Effective Tax Rate (ETR). The article specifies valuation at the lower of the minimum tax rate or the applicable domestic rate, outlines exclusions for certain pre-existing Kuwaiti laws, and sets conditions for asset transfers occurring after 30 November 2021.