Ministerial Decision No. 55 of 2025, implementing Kuwait's DMTT framework under Decree-Law No. 157 of 2024, details specific tax neutrality rules in Article 59. It outlines the optional 'Equity Investment Inclusion Election', requiring adjustments to GloBE income and covered taxes for associated gains or losses. The Article provides distinct treatment for 'Qualified Flow-through Tax Benefits' linked to Qualified Ownership Interests, specifying how such benefits impact the owner's Adjusted Covered Taxes. It sets rules for when an owner's investment is reduced to zero and introduces an irrevocable election for a proportional amortization method.