Ministerial Decision No. 55 of 2025 implements Kuwait's DMTT framework under Decree-Law No. 157 of 2024. Article 7 establishes the critical rules for determining the tax location of a Constituent Entity. It provides specific criteria for standard entities based on tax residency or place of creation, for flow-through entities, and for various types of Permanent Establishments. For dual-located entities, the Article outlines a clear hierarchy of tie-breaker rules, prioritising applicable tax treaties, then the amount of Covered Taxes paid, and finally the Substance-Based Income Exclusion (SBIE).