Law & Regulation
Domestic Minimum Top-up Tax Law
Issued 1 September 2024, introduces a Domestic Minimum Top-up Tax for multinational-enterprise groups with global consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years, aligned with the OECD Global Anti-Base Erosion (GloBE) Model Rules. Effective for financial years starting on or after 1 January 2025, targeting a 15% minimum effective tax rate.
Legal Significance
What This Instrument Does
Imposes a jurisdictional top-up tax on large in-scope multinational groups operating in Bahrain where their aggregated Bahraini effective tax rate falls below 15%.
Why It Matters
The first general corporate-tax-adjacent instrument affecting large multinational sponsors, contractors and financiers active in Bahrain's infrastructure market — directly relevant to any qualifying group among this dataset's participants.
Legal Framework Position
- TaxPrimary / Framework Instrument
Instrument Overview
- Official Citation
- Decree-Law No. (11) of 2024
- Instrument Type
- Decree
- Enactment Date
- 1 September 2024
- Effective Date
- 1 January 2025
- Last Verified
- 30 September 2026
Recent Developments
- Regulatory · 1 January 2025Bahrain Domestic Minimum Top-up Tax takes effect
Bahrain's Domestic Minimum Top-up Tax (Decree-Law 11/2024), issued 1 September 2024, takes effect for financial years starting on or after 1 January 2025 — the event date used here is the law's own effective date, not its earlier publication date.
