GTL Summary:

Article 3 defines the scope of the Domestic Minimum Top-Up Tax, targeting Multinational Enterprise Groups that meet specific revenue thresholds. Pursuant to Paragraph C, the Revenue Test is met if an MNE Group reports annual revenue of EUR 750 million or more in at least two of the four preceding fiscal years. The tax is payable by a Filing Constituent Entity on behalf of entities, joint ventures, and subsidiaries located in Bahrain. Additionally, Article 3 mandates the payment of Additional Current Tax and Additional Tax for Permanent Differences, as calculated under the specific provisions of Article 9, to ensure comprehensive tax coverage.

Document Type: Tax Law Article
Law: DMTT Law (Decree Law No. 11 of 2024)
Article Number: 3
Country: 🇧🇭 Bahrain
Location: Chapter 2 - Scope and Imposition of the Tax
Order: 3
Last updated at: 2026-02-23 12:13:40 UTC

Chapter 2 - Scope and Imposition of the Tax

Article 3 - Scope of the Tax

  1. Tax shall be imposed on Taxable Income for the Fiscal Year and is payable by a Filing Constituent Entity on behalf of a Constituent Entity located in the Kingdom which is a member of a Multinational Enterprise Group that meets the Revenue Test described in Paragraph C of this Article.

  2. Tax shall be imposed on Taxable Income for the Fiscal Year and is payable by a Filing Constituent Entity on behalf of a Joint Venture and its Joint Venture Subsidiaries which are located in the Kingdom, if any, where the Ultimate Parent Entity of the Joint Venture or Joint Venture Subsidiary is an Ultimate Parent Entity of a Multinational Enterprise Group that meets the Revenue Test described in Paragraph C of this Article.

  3. The Revenue Test for the Fiscal Year is considered met if the annual revenue of the Multinational Enterprise Group is equal or exceeds EUR 750 million in the Consolidated Financial Statements of the Ultimate Parent Entity for at least two of the four Fiscal Years immediately preceding that Fiscal Year. If one or more of the four Fiscal Years is longer or shorter than 12 months, the revenue threshold shall be adjusted proportionately for each of those Fiscal Years.

  4. Notwithstanding the provisions of Article 4, the revenue of Excluded Entities shall be taken into consideration for the purpose of determining whether the Revenue Test has been met.

  5. The Filing Constituent Entity shall pay Additional Current Tax and Additional Tax for Permanent Differences as calculated according to Paragraphs D and F of Article 9 of this Law, in addition to any amount due under the provisions of Paragraphs A, B, and C of this Article.

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