NBR Releases new DMTT Computation & Transfer Pricing Guides

The National Bureau for Revenue (NBR) has released two important guides aimed at helping MNE groups navigate Bahrain’s Domestic Minimum Top-up Tax (DMTT) framework:

📑 DMTT Computation Guide

📑 Transfer Pricing Guide

These publications provide much-needed practical guidance on the application of Bahrain’s DMTT regime and the associated transfer pricing requirements for in-scope entities.

Key highlights from the DMTT Computation Guide:

▪ Step-by-step approach to computing DMTT liability

▪ Guidance on CFS and deemed consolidation requirements

▪ Determination of Financial Accounting Income or Loss (FANIL)

▪ Treatment of permanent and temporary differences

▪ Computation of covered taxes, taxable income and top-up tax

▪ Special rules for investment entities, insurance investment entities and corporate restructurings

Key highlights from the Transfer Pricing Guide:

▪ Application of the Arm’s Length Principle

▪ Detailed comparability analysis framework

▪ Guidance on OECD-recognized transfer pricing methods

▪ Documentation requirements relating to Local File and Master File

These guides are a significant step towards providing greater clarity on Bahrain’s evolving international tax framework and will assist MNE groups in strengthening their DMTT and transfer pricing compliance processes.

At Moore Bahrain, we encourage businesses to review these publications carefully and assess the potential impact on their current tax governance, transfer pricing policies, and DMTT compliance obligations.

📖 Access the guides here:

DMTT Computation Guide: https://lnkd.in/dihsHDc3

Transfer Pricing Guide: https://lnkd.in/dGf5CR59

For any assistance regarding VAT implications, reach out to Moore Bahrain at tax@msbahrain.com or call +973 17200144.