Ministerial Decision No. 55 of 2025 provides the executive regulations for Kuwait's DMTT framework. Article 49 specifically addresses the calculation of the Effective Tax Rate (ETR) and Top-up Tax for Minority-Owned Constituent Entities (MOCEs). It mandates that MOCEs, whether part of a Minority-Owned Subgroup or standalone, must compute their ETR and any resulting Top-up Tax as if they were a separate MNE Group. Consequently, their Adjusted Covered Taxes and GloBE Income are excluded from the main MNE Group’s calculations. This provision excludes Investment Entities.