Implementation Of Tax On Multinational Enterprises In Bahrain

On 1 September 2024, Bahrain's National Bureau of Revenue (BNBR) published Decree-Law No. (11) of 2024 Issuing the Implementation of Tax on Multinational Enterprises (Law). The Law introduces a Domestic Minimum Top-Up Tax (DMTT) to entities of multinational enterprises (MNE) located in Bahrain to pay a global minimum tax of 15% if the annual revenue equals or exceeds EUR 750 million in accordance with the Organisation for Economic Cooperation and Development (OECD) guidelines. This Law is set to be effective on 1 January 2025.

Scope of Application

The Law is applicable to entities of MNE groups located in Bahrain, including companies, branches, and permanent establishments, with annual revenue equal to or exceeding EUR 750 million in the consolidated financial statements of the Ultimate Parent Entity (UPE) for at least two of the four fiscal years.