Ministerial Decision No. 55 of 2025, implementing Kuwait's DMTT framework, defines the scope of 'Eligible Payroll Costs' in Article 44. These costs are integral to calculating the Substance-Based Income Exclusion. The definition encompasses employee compensation such as salaries, benefits, and social security contributions, provided they are reflected in financial statements for determining FANIL. The Article explicitly excludes capitalised payroll costs and those allocated to excluded international shipping income. It also defines 'Eligible Employees', including certain independent contractors, and mandates a pro-rata formula for part-time activities in Kuwait.