Safe harbours in Bahrain DMTT
Can we use a safe harbour to avoid full DMTT calculations?
The situation
The DMTT framework allows simplifications and safe harbours, with conditions. Advisers recommend reassessing eligibility each year.
The law
- DMTT Regulations (Decision No. 172 of 2024): Registration through the NBR portal: by 31 December 2025 for groups already in scope, otherwise within 120 days of the start of the first in-scope year
- 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
If a safe harbour applies, top-up can be deemed nil or computed more simply. Eligibility depends on data such as country by country reporting figures. Low taxed Bahrain profits often fail the effective rate test, so check carefully.
What to do
- Pull CbCR data for Bahrain.
- Test each safe harbour.
- Document the result.
- Elect if eligible.
We can do this for youDMTT advance payments, top-up tax return and payment: BHD 6,000