Draft CIT and DMTT together

The situation

The DMTT applies from 2025 to large MNE groups. Public summaries of the CIT draft do not explain how the two interact.

The law

• Decree-Law No. 11 of 2024 on tax on multinational enterprise groups (DMTT Law): 15% domestic minimum top-up tax for MNE groups with consolidated revenue of EUR 750 million or more in two of the four prior years, from fiscal years starting on or after 1 January 2025
• Draft Corporate Income Tax Law (not yet enacted): Proposed 10% tax on taxable income above BHD 200,000 for residents with revenue over BHD 1 million or taxable income over BHD 200,000, expected from 1 January 2027

What it means for you

A 10% CIT would count as a covered tax for GloBE, which could reduce DMTT top-up. Until the interaction rules are published, model both and avoid double counting. Group tax teams should track both regimes together.

What to do

1. Model DMTT today.
2. Model DMTT plus draft CIT.
3. Track interaction rules.
4. Update forecasts.

Related

• Late filing penalty proposed in Bahrain CIT
• Preparing systems for Bahrain CIT
• Oil and gas companies under the Bahrain draft
• Is Bahrain corporate income tax in force
• Small business and nil CIT returns
• Who would pay the proposed Bahrain CIT