Bahrain

On 1 September 2024, Bahrain published Decree 11 of 2024, which introduces a Domestic Minimum Top-up Tax for Multinational Enterprises (hereinafter referred to as ‘DMTT Law’). The DMTT Law provides the legislative basis for the introduction and implementation of a DMTT in Bahrain, and it is intended to be consistent with the Organisation for Economic Co-operation and Development (OECD) Global Anti-Base Erosion (GloBE) Model Rules. The DMTT Law applies to fiscal years commencing on or after 1 January 2025. See Domestic Minimum Top-up Tax in the Taxes on corporate income section for more information.

It should be noted that the DMTT Law does not include an Income Inclusion Rule (IIR) or an Undertaxed Payments Rule (UTPR), the other key charging mechanisms as prescribed by the GloBE Model Rules.