Bahrain’s National Bureau for Revenue has issued DMTT filing guidance for large MNE Groups, covering return submission, payments and refunds under the 15% Domestic Minimum Top-up Tax (DMTT), with the first filing deadline set for 31 March 2027.
Bahrain’s National Bureau for Revenue (NBR) has published Version 1.0 of its DMTT Return Filing Manual, setting out procedures for filing, payment and refunds under the 15% Domestic Minimum Top-up Tax (DMTT). The regime applies from 1 January 2025 to qualifying large MNE Groups operating in Bahrain.
DMTT scope and legislation
The DMTT applies where an MNE Group’s consolidated group revenue is equal to or exceeds EUR 750 million in at least two of the four fiscal years preceding the reporting fiscal year.
The regime was introduced through Decree-Law No. 11 of 2024 (the DMTT Law) and regulated by Decision No. 172 of 2024 (the DMTT Regulations).
Filing requirements
The manual explains the Revenue Test Notification, DMTT Tax Return, Central Filing Notification and Information Schedule. It also provides instructions for navigating the NBR online portal to submit returns, make payments and request refunds.
Every registered Filing Constituent Entity must submit a Revenue Test Notification for each reporting fiscal year. Where the EUR 750 million threshold is met, the entity must proceed with a full DMTT Tax Return.
Where the threshold is not met, the entity must select the relevant out-of-scope option and provide details of the group’s annual revenues for the four preceding fiscal years. Any advance payments can be treated as Excess Tax Credits and may be refunded or offset against other tax liabilities or administrative fines.
Central and local filing
The DMTT Tax Return contains a Central Filing Notification, Information Schedule and Tax Computation Schedule.
Through the Central Filing Notification, a group can inform the NBR that its standardised GloBE Information Return (GIR) will be submitted in another jurisdiction that has an active Qualifying Competent Authority Agreement with Bahrain.
Where Central Filing applies, the local entity does not initially need to complete the local Information Schedule. However, if the GIR is not received through international exchange within three months of the filing deadline, the Information Schedule requirement is reinstated and the entity must update its return.
For Local Filing, the entity must submit the required Information Schedule. This can involve a full standardised GloBE Information Return (GIR) or a Local DMTT Information Schedule containing Bahrain-specific information. The schedule must be uploaded as an XML file that complies with the official OECD GIR XML schema.
DMTT liability calculation
The Tax Computation Schedule is used to calculate the final DMTT liability. Filing Constituent Entities must provide subgroup information covering Constituent Entities, including Joint Ventures, Stateless Entities, Investment Entities and Minority-Owned Constituent Entities.
The calculation takes account of exclusions where a different Filing Constituent Entity has been appointed for particular subgroups. Advance payments and Excess Tax Credits carried forward from previous periods are also considered in determining the final amount payable or reclaimable.
Additional tax resulting from retroactive adjustments to previous years is recorded separately under the “Corrections from previous year(s)” table and does not directly affect the current year’s liability calculation.
Filing deadline
The DMTT Tax Return must generally be submitted within 15 months after the end of the Reporting Fiscal Year. Where the deadline falls on an official holiday, the filing date is extended to the next working day.
For the reporting fiscal year ending on 31 December 2025, the first DMTT filing deadline will be 31 March 2027.
All DMTT filings must be completed through the NBR online portal. The manual also provides examples and step-by-step instructions for completing the relevant forms and submitting the required information.
