The guidance clarifies scope, exclusions, and safe harbors.
Bahrain’s National Bureau for Revenue (NBR) published an updated guidance on 12 August 2025 concerning the 15% Domestic Minimum Top-Up Tax (DMTT), effective from 1 January 2025.
The updates include an expanded Entities in Scope of DMTT Guide and a revised DMTT Advance Payment Manual, providing clarity on exclusions, safe harbors, currency conversion, and the advance payment process.
The guidance outlines which Constituent Entities of Multinational Enterprise Groups in Bahrain fall under the DMTT Law, particularly for groups meeting the EUR 750 million Revenue Test. It also covers Joint Ventures, their subsidiaries, and certain Excluded Entities whose revenue still counts toward the Revenue Test.
Additionally, the guide explains “De Minimis Exclusions” and safe harbor provisions that may reduce or eliminate DMTT liability for eligible entities.
NBR emphasises that the guide is informational, non-binding, and should be used alongside the DMTT Law, Executive Regulations, and relevant OECD guidance.
