GTL Summary:

Specifies how to determine the location of a Constituent Entity that is a Permanent Establishment based on Tax Treaty allocation, net basis income taxation, or physical situation.

Document Type: ERS - Executive Regulations
Law: DMTT Law (Decree Law No. 11 of 2024)
Decision Number: executive-regulations-172-article-6
Year: 2024
Country: 🇧🇭 Bahrain
Official Name: Article 6 - Location of a Constituent Entity that Is a Permanent Establishment
Last updated at: 2026-02-23 12:13:40 UTC

Chapter 3 - Location of an Entity

Article 6 - Location of a Constituent Entity that Is a Permanent Establishment

For the purposes of applying the provisions of Article 5 of the Law, the location of a Constituent Entity that is a Permanent Establishment shall be determined as follows:

  1. Where the Constituent Entity is a Permanent Establishment in accordance with Paragraph A of the definition of a Permanent Establishment under Article 1 of the Law, it shall be located in the jurisdiction in which it is treated as a Permanent Establishment and to which the Tax Treaty allocates taxing rights.

  2. Where the Constituent Entity is a Permanent Establishment in accordance with Paragraph B of the definition of Permanent Establishment under Article 1 of the Law, it shall be located in the jurisdiction where it is subject to net basis income taxation based on its place of business or deemed place of business.

  3. Where the Constituent Entity is a Permanent Establishment in accordance with Paragraph C of the definition of Permanent Establishment under Article 1 of the Law, it shall be located in the jurisdiction where it is situated.

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