GTL Summary:

Article 16 addresses the tax implications of corporate restructuring and transfers of assets or liabilities within a Multinational Enterprise Group. It mandates that the Executive Regulations will define the specific rules and controls for entities joining, merging, or leaving a group. These rules will also cover the complexities of multi-parented MNE groups and holding structures. The overarching requirement is that all restructuring-related tax treatments must remain consistent with the OECD Pillar Two Model Rules, administrative guidance, and relevant international commentary, ensuring that organizational changes do not unfairly circumvent the 15% Domestic Minimum Top-Up Tax obligations in Bahrain.