🇧🇠Tax1 Sep 2024
Bahrain brings in a 15% domestic minimum top-up tax for large multinationals from 2025
Bahrain's Decree-Law No. 11 of 2024, published on 1 September 2024, imposes a 15% domestic minimum top-up tax on Bahraini entities of multinational groups with revenue above EUR 750 million in two of the last four years, for fiscal years starting on or after 1 January 2025. It was the first such tax in the Gulf. Bahrain has no general corporate income tax for other businesses.
The National Bureau for Revenue (NBR) administers the tax.
What changed
- Bahraini constituent entities of in-scope multinational groups, including branches, must pay at least 15% tax on their profits, following the OECD's Pillar Two rules.
- It applies to fiscal years starting on or after 1 January 2025.
- It does not tax foreign subsidiaries of Bahrain-headquartered groups.
- The NBR issued implementing regulations (Decision No. 172 of 2024) on 15 December 2024 and opened registration. December year-end groups had to register by 30 January 2025.
Later developments
The NBR's filing manual of September 2026 sets the first return deadline for 2025 year ends. Sources disagree on the transition-year date, so check the NBR portal.
Who is affected
Bahraini entities of large multinational groups and their tax teams.