Bahrain: Legislation implementing Pillar Two global minimum tax rules

Key features of the new law and an overview of how the domestic minimum top-up tax is calculated

September 5, 2024

Decree-Law No. (11) of 2024 implementing a 15% domestic minimum top-up tax (DMTT) on multinational enterprises (MNEs) located in Bahrain effective January 1, 2025, was released on September 1, 2024.

The DMTT law contains key operative provisions of the OECD Pillar Two global anti-base erosion model (GloBE) rules, making Bahrain the first Gulf Cooperation Council (GCC) country to implement a global minimum tax aligned with the Pillar Two framework.

The executive regulations and decisions for implementation and enforcement of the DMTT will be released after Cabinet approval. The regulations will prescribe detailed rules, conditions, and procedures for implementing the DMTT in a manner consistent with the GloBE rules, guidance, and commentary issued by the OECD.

Read a September 2024 report prepared by the KPMG member firm in Bahrain that discusses the key features of the new law and provides an overview of how the DMTT is calculated.

Read an October 2024 report prepared by the KPMG member firm in Bahrain that outlines certain “frequently asked questions” (FAQs) in relation to the DMTT.  

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