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Bahrain Introduces Domestic Minimum Top-Up Tax Regulations

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The legislation establishes a Domestic Minimum Top-Up Tax (DMTT) aimed at ensuring that entities of multinational enterprises (MNEs) operating in Bahrain contribute a global minimum tax rate of 15% on their profits. This global minimum tax is a key component of Pillar Two of the Organisation for Economic Cooperation and Development OECD Inclusive Framework addressing Base Erosion and Profit Shifting (BEPS) projects.

The DMTT will take effect for fiscal years starting on or from 1 January 2025.

Key Provisions

  • The legislation will be applicable to multinational enterprises (MNEs) conducting business in Bahrain that have a consolidated annual revenue exceeding €750 million in two of the last four fiscal years.
  • The applicable tax rate is set at 15% and will be levied on the financial net accounting income with certain adjustments permitted. The financial net accounting income refers to the figure disclosed in the financial statements that are prepared in compliance with international accounting standards.
  • Filing entities will need to register with the National Bureau for Revenue and file a tax return. The DMTT will be payable in installments, which will include advance payments due in 2025. Additional regulations will be issued to provide comprehensive guidelines on the registration, filing, payment processes, and timelines.
  • Specific entities are exempt from the DMTT Law, including government agencies, international organizations, non-profit entities, pension funds, and various investment funds and real estate investment entities. The revenues of these excluded entities must be factored in when determining the €750 million revenue threshold.

Pascale Dona
By Pascale Dona
Senior Legal Editor

Pascale Dona joined Thomson Reuters in 2014 as Content Specialist. In 2007, Pascale graduated from the Lebanese University with a Bachelor’s Degree in Law, then moved to France and completed her Master’s degree in International Law from Nice Sophia Antipolis University. Pascale has more than 10 years of experience as legal Specialist in Lebanon and UAE. She is a native Arabic speaker and proficient in English and French.

Pascale is currently a Senior Legal Editor for Thomson Reuters MENA. She is based in Dubai and is responsible for maintaining and providing the latest legal content for the MENA region.

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