How the Bahrain DMTT top-up is worked out

How is the 15% Bahrain top-up tax calculated in simple terms?

The situation

DMTT tops up the Bahrain jurisdictional effective tax rate to 15% using the GloBE rules.

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

What it means for you

Steps: compute GloBE income for Bahrain entities, compute covered taxes, find the effective rate, and apply the top-up percentage to excess profit after the substance based income exclusion. Example: GloBE income BHD 10m, covered taxes BHD 0.3m, ETR 3%, top-up 12%. If the carve out is BHD 1m, top-up = 12% x BHD 9m = BHD 1.08m.

What to do

  1. Compute GloBE income by entity.
  2. Compute covered taxes.
  3. Apply the carve out.
  4. Compute top-up at 15% less ETR.

We can do this for youDMTT advance payments, top-up tax return and payment: BHD 6,000

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