Bahrain's Domestic Minimum Top-up Tax
Bahrain has no general corporate income tax; only oil and gas companies are taxed. From financial years beginning on or after 1 January 2025, however, constituent entities of multinational groups with consolidated revenue of EUR 750 million or more in at least two of the previous four years pay a Domestic Minimum Top-up Tax that brings their effective rate in Bahrain to 15%, under Decree-Law No. 11 of 2024.
Key facts
| General corporate tax | None (oil and gas companies excepted) |
|---|---|
| DMTT rate | Top-up to a 15% effective rate |
| Scope | MNE groups with revenue of EUR 750 million or more in two of the four preceding years |
| In force | Financial years beginning on or after 1 January 2025 |
| Law | Decree-Law No. 11 of 2024 |
| Authority | National Bureau for Revenue (NBR) |
Opens the assistant with Bahrain already selected. Answers cite the law, guidance and cases they rest on.
How the tax follows the OECD model
The DMTT computes GloBE income and covered taxes for the Bahraini entities of the group using the OECD Pillar Two model rules, applies the substance-based income exclusion and charges the difference between the jurisdictional effective rate and 15%. Because Bahrain designed it as a qualified domestic top-up tax, the tax is intended to be credited in full against any top-up the parent's country would otherwise collect.
Deductions, filing and objections
Whether an accounting item such as an expected credit loss provision reduces GloBE income depends on the model rules' treatment of the item rather than on local accounting, and the NBR's executive regulations and guides set the filing calendar, advance payments and the fee and time limit for objecting to an assessment. The assistant quotes the regulation article on each.
Frequently asked questions
- Does Bahrain have corporate income tax?
- Not a general one. Oil and gas companies are taxed, and from 2025 large multinational groups pay the 15% Domestic Minimum Top-up Tax.
- Who is within Bahrain's DMTT?
- Bahraini entities of groups with consolidated revenue of EUR 750 million or more in at least two of the preceding four financial years.
Primary sources
- National Bureau for Revenue (NBR)
- OECD — Global minimum tax (Pillar Two)
- National Bureau for Revenue (NBR)
Related guides
Disclaimer: This page provides general tax information based on publicly available primary sources, reviewed on the date shown. Rules are conditional and change; the page may not reflect a change made after that date, and it is not a substitute for advice from a qualified tax professional on your specific situation.