This regulatory guide (Version 1.1, May 2025), published by the National Bureau for Revenue (NBR) of Bahrain, establishes the parameters for entities falling within or excluded from the scope of the Domestic Minimum Top-up Tax (DMTT) under Decree-Law No. 11 of 2024. It details the operational definitions for Multinational Enterprise (MNE) Groups, Ultimate Parent Entities (UPEs), and Constituent Entities based on accounting consolidation under acceptable financial standards like IFRS. The guide provides specific rules for the global EUR 750 million revenue test, detailed treatments for Joint Ventures, and outlines specific criteria for statutory 'Excluded Entities' such as government bodies, non-profit organizations, and sovereign wealth funds.
Entities in Scope of DMTT Guide
Kingdom of Bahrain — National Bureau for Revenue
Version 1.1 | May 2025
Updated on: 12 August 2025
Contents
Updates to this guide
1. Introduction
1.1 Background
1.2 Purpose of this Guide
1.3 Overview of the scope of the DMTT Law
2. Entities within the Scope
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