Under the Kuwait Income Tax Decree of 1955, as amended by Law No. 2 of 2008 (“tax law”), all entities (either local or foreign) carrying out trade or business in Kuwait are taxable. However, in practice, the tax law has not been applied to entities incorporated in member states of the Gulf Corporation Council (“GCC”) [comprising Saudi Arabia, UAE, Qatar, Oman, Bahrain and Kuwait] provided that they are owned by individuals who do not represent foreign companies or are owned by GCC companies that are in turn owned by individuals. Accordingly, the Kuwait tax law has been applied only on foreign entities and their shareholding in local entities or in GCC entities carrying out trade or business in Kuwait or earning taxable income from Kuwait.