Bahrain: Country-by-country obligations extended to 28 February 2022

The first reporting year is 31 December 2021.

The first reporting year is 31 December 2021.

The Ministry of Industry Commerce and Tourism (MoICT) notified Bahrain companies on their country-by-country (CbC) notification and reporting obligations indicating that the filing window will be open until 28 February 2022.

The ministerial order regarding CbC reporting issued in early 2021 states that CbC obligations apply for financial years commencing from 1 January 2021 with the first notification due at the end of December 2021, which now appears to be extended to 28 February 2022.

However, recent correspondence from the MoICT has stated that they consider the first reporting year to be 2020 (i.e., the CbC information that needs to be reported by the 28 February 2022 deadline is for the year ending 31 December 2020). The MoICT has also stated that they have directly approached the entities that have to file the CbC notification and report. 

KPMG observation

  • Under Article 2 of the ministerial order, the first reporting year is 31 December 2021, not the financial year ended 2020.
  • Under Article 3(a) of the ministerial order, the CbC notification deadline for the year ended 31 December 2021 was 31 December 2021 (which now appears to be extended to 28 February 2022).
  • Under Article 4 of the ministerial order, the CbC reporting deadline for the year ended 31 December 2021 is 31 December 2022 (which presumably is unchanged).
  • The National Bureau for Revenue (NBR) is yet to release any information on the specific requirements for CbC notifications through the International Tax Information Exchange System (ITIES) portal. The ITIES portal through which the CbC notifications and reporting is to be done allows only for reporting but does not seem to allow entities only seeking to submit a CbC notification.
  • The NBR page on CbC reporting still states “coming soon.” When logging into the NBR ITIES portal, a new CbC reporting guide is available. However, the guide is still unclear on whether notifications will still be required for Bahrain constituent entities of multinational enterprise (MNE) groups headquartered outside Bahrain.

Read a January 2022 report [PDF 133 KB] prepared by the KPMG member firm in Bahrain


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