Ministerial Decision No. 55 of 2025 establishes Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 62 introduces a Transitional Country-by-Country Reporting (CbCR) Safe Harbor, aligning with OECD Pillar Two guidance. This provision allows an MNE Group's Top-Up Tax to be deemed zero for tax periods until 31 December 2026. To qualify, MNEs must file a qualified CbCR and meet one of three tests: a de minimis threshold (<€10m revenue), a simplified Effective Tax Rate (ETR) test, or a routine profits test.