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July 2, 2026

This administrative guide (Version 1.1, July 2025), published by the National Bureau for Revenue (NBR) of Bahrain, outlines the operational compliance procedures for the Domestic Minimum Top-up Tax (DMTT) under Decree-Law No. 11 of 2024. It details the administrative lifecycle for in-scope Multinational Enterprises (MNEs) and Joint Ventures, covering mandatory registration (within 120 days of the fiscal year-end), deregistration criteria, and the appointment and responsibilities of a Filing Constituent Entity. Additionally, the guide explains the rules for annual and five-year statutory elections, the quarterly calculation mechanics for advance tax payments (Prior Year vs. Current Year methods), 5-to-10-year record retention durations, audit and self-assessment correction procedures, and the multi-tiered tax dispute resolution framework, concluding with a comprehensive schedule of administrative fines and criminal penalties for tax evasion.

DMTT Administrative Guide

Kingdom of Bahrain — National Bureau for Revenue

Version 1.1 | May 2025

Updates to this guide

1. Introduction
1. 1.1 Background
2. 1.2 Purpose of this guide
2. Registration
1. 2.1 Introduction
2. 2.2 Registration obligations
3. 2.3 Registration documentation
  1. 2.3.1 Changes in information
4. 2.4 Excluded Entities
3. Deregistration
1. 3.1 Mandatory deregistration
2. 3.2 Timing and method for deregistration
3. 3.3 Deregistration by the NBR
4. Filing Constituent Entity
1. 4.1 Introduction
2. 4.2 Appointing a Filing Constituent Entity
3. 4.3 Responsibilities of a Filing Constituent Entity
4. 4.4 Changing a Filing Constituent Entity
5. Elections
1. 5.1 Introduction
2. 5.2 Overview of Elections provided under the DMTT framework
  1. 5.2.1 Five-Year Elections
  2. 5.2.2 Annual Elections
3. 5.3 Making and revoking an Election
6. Payment of Tax
1. 6.1 Introduction
  1. 6.1.1 Determining Advance Payment Periods
  2. 6.1.2 Due dates for advance tax payments
2. 6.2 How to calculate the Advance Tax Payment
  1. 6.2.1 Introduction
  2. 6.2.2 Prior Year Method
  3. 6.2.3 Current Year Method
  4. 6.2.4 Computation of the reasonable estimate of Tax
3. 6.3 Documenting advance tax payments
4. 6.4 Payment of the balance of Tax Due
7. Currency Considerations
1. 7.1 Introduction
2. 7.2 Currency conversion for Tax computation
3. 7.3 Currency for reporting and paying Tax
4. 7.4 Conversion of amounts expressed in Euro
5. 7.5 Reliable sources for foreign exchange rates
6. 7.6 Documentation requirements
8. Tax Refunds
1. 8.1 Eligibility criteria
2. 8.2 Refund Procedure
9. Joint Liability
1. 9.1 Constituent Entities and Joint Ventures / Joint Venture Subsidiaries
2. 9.2 Entities joining or leaving a Multinational Enterprise Group
10. Retention of Records
1. 10.1 General requirements
2. 10.2 Record keeping periods
3. 10.3 Manner of retaining records
11. Revenue Test notification
12. Calculation of deadlines
13. DMTT Audits
1. 13.1 Definition
2. 13.2 Where and when an audit takes place
3. 13.3 Knowing that a DMTT audit is taking place
4. 13.4 NBR powers during a Tax audit
5. 13.5 Results of an audit
14. Assessment of Tax Due
15. Tax Dispute Resolution
1. 15.1 Introduction
2. 15.2 Independent review by the NBR
3. 15.3 Objection to the Tax Objections Committee
4. 15.4 Appeal to competent court
16. Tax Agents
1. 16.1 Introduction
2. 16.2 Becoming an authorised Tax Agent
17. Fines and Penalties

Preface

This guide sets out general principles relating to the administrative aspects of the Domestic Minimum Top-up Tax (DMTT).

Contents

Preface