DMTT scoping, NBR registration and Revenue Test Notification

We test the EUR 750 million revenue rule, map every Bahrain constituent entity, pick the filing entity, register on the NBR portal and file the yearly Revenue Test Notification.

BHD 2,500One time, then yearly notification

For: Bahrain entities and branches of multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four previous years, including Indian groups with Bahrain subsidiaries.

What we need from you

Group consolidated revenue for the four prior years
Revenue test
Group structure chart with ownership
Identify constituent entities
Bahrain entity CRs and branches
Registration list
Joint ventures at least 50% owned
May be in scope
Ultimate parent fiscal year
Timeline
Excluded entity candidates (funds, pension, government)
Exclusions

What we discuss

Did consolidated revenue reach EUR 750 million in two of the last four years?
Decides scope
Which Bahrain entity will be the filing constituent entity?
One files for the group in Bahrain
Any acquisitions or disposals during the year?
Changes scope and dates
Are you using safe harbours or exclusions?
Affects registration information

What we file

Revenue test working
Example: revenue EUR 820m, 640m, 790m, 700m: two of four years at or above EUR 750m, so in scope
Register the filing entity and constituent entities
File the Revenue Test Notification

What you get

Scoping memo
NBR registration confirmation
Compliance calendar for advance payments and return

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 Source
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 Source

Questions people ask

Online payment in BHD is not open yet. Send us a message and an adviser for Bahrain confirms the scope and the fee before any work starts.