On 8 June 2026, Bahrain’s National Bureau for Revenue published its DMTT Computations Guide, a document setting out how Domestic Minimum Top-up Tax liabilities should be calculated for entities within scope of the global minimum tax regime.

If you operate a business in Bahrain, or advise one, this is worth understanding.

What is the DMTT?

Bahrain introduced the Domestic Minimum Top-up Tax through Decree-Law No. (11) of 2024. It came into effect on 1 January 2025. The DMTT is part of the OECD’s Pillar Two global minimum tax framework, designed to ensure large multinational enterprise groups pay a minimum effective tax rate of 15% in every jurisdiction where they operate.

The threshold is €750 million in consolidated global revenue across at least two of the last four fiscal years. So in its current form, the DMTT applies to large MNE groups, not local SMEs directly. But the compliance and advisory activity it generates affects the broader Bahrain business services market, and awareness matters for anyone operating in the ecosystem.

For a jurisdiction that historically had no corporate income tax on most sectors, this is a material shift.

What does the new Computations Guide cover?

The guide is the NBR’s current view on how DMTT liabilities are actually calculated. Key areas covered:

  • GloBE income and loss calculations, meaning how to arrive at the adjusted financial net income or loss per constituent entity
  • Covered taxes and how they factor into the effective tax rate
  • Substance-based income exclusions, which are carve-outs for payroll costs and tangible assets that can reduce the amount subject to top-up tax
  • Safe harbour provisions, including transitional CbCR safe harbours that simplify compliance for qualifying groups
  • The de minimis exclusion, available where revenue and income in a jurisdiction fall below specified thresholds
  • Special entity categories including joint ventures, investment entities, and excluded entities

The NBR has been explicit that the guide is informational and does not cover every scenario. It is meant to be read alongside the DMTT Law and Executive Regulations, not as a standalone compliance tool.

Who needs to pay attention?

The direct DMTT obligation sits with large MNE groups. But the knock-on effect is wider.

If you are a CFO, finance director, or financial controller at a Bahrain subsidiary of a qualifying group, your group’s tax and compliance team needs to be across this. Advance payments are already due for FY2025, Q1 and Q2 together within 60 days of Q2 end. The first annual return deadline is 30 June 2027, which sounds distant, but the underlying GloBE calculations, data gathering, and NBR registration all need to happen well before that.

If you are a Bahrain-based business adviser, accountant, or compliance professional, this is part of the regulatory landscape you are operating in. Your clients may be asking questions about it, or may be affiliates of groups that are in scope.

Safe harbours and exclusions

Not every entity within a qualifying MNE group will end up with a tax liability.

The de minimis exclusion applies where average Bahrain revenue is below €10 million and average GloBE income is below €1 million for the fiscal year. Transitional CbCR safe harbours can also materially reduce compliance burden for certain groups during the early years of the regime.

Whether those positions are available depends on the entity’s actual numbers and structure. They should be assessed, not assumed.

The broader point

Bahrain has moved quickly on Pillar Two. The law is enacted, the executive regulations are published, and the NBR has now added a computations guide to the framework. The regime is substantially built out.

What tends to lag is the entity-level response, particularly for regional operations where Bahrain is not the group’s primary jurisdiction. The new guide is a signal that the NBR expects compliance to be active, not passive.

If you have not yet scoped how DMTT applies to your entity or your clients, now is a reasonable time to start.

SRR Consultants advises businesses and multinationals operating in Bahrain on regulatory and financial compliance. If you want to understand how the DMTT framework applies to your situation, get in touch.