It targets large multinational enterprise groups, not a Bahrain company merely because it carries on business.
Madar's third tax workstream
Domestic Minimum Top-up Tax
For multinational enterprises — a hub connecting Bahrain legislation with official guidance and Pillar Two concepts, while referring complex cases requiring professional judgement to a specialist.
What the user should understand first
This is not a general corporate tax on every business
The short label can mislead, so Madar starts with the target population and the limits of any result before offering a tool or calculator.
The scope threshold starts at annual global revenue of at least EUR 750 million, subject to the full statutory and regulatory test.
The rules aim for an effective tax rate of at least 15% on profits arising in Bahrain under the prescribed computation methodology.
The tax entered into force on 1 January 2025; the fiscal period and group structure must be checked before determining an obligation.
EUR 750 million is not a complete answer by itself: the revenue test, group status, constituent and excluded entities and fiscal period must be assessed under the current legislation and guidance.
First practical workflow available
Start the scope and registration workflowCheck scope, identify the filing entity and registration date
Five points move from group status and the Revenue Test to Bahrain nexus, exclusions and Filing Constituent Entity appointment, followed by a deadline helper and application checklist.
Second practical workflow available
Start the zero-tax routeUnderstand when tax may be zero despite being in scope
The workflow distinguishes the de minimis exclusion, Transitional CbCR Safe Harbour, initial international activity and full computation, while showing the registration, filing and record obligations that remain.
Third practical workflow available
Start the annual filing workflowMove from the Revenue Test Notification to return and settlement
The workflow covers the annual notification, all three return parts, central or local filing and the 15-month deadline, kept separate from the three-month receipt checkpoint.
Fourth practical workflow available
Start the full computationTurn accounting and tax data into an ETR and Tax Due
An interactive reconciliation sheet orders all twelve computation steps, separates special computation buckets and applies the substance rates for the fiscal-year start.
Fifth practical workflow available
Start the transfer-pricing workflowTest the arm's-length position and prepare both documentation files
The workflow separates cross-border transactions from the domestic asset-transfer exception and orders the comparability factors, five methods, Local File and Master File before an adjustment enters the computation.
Sixth practical workflow available
Start payment and settlementTurn the fiscal year into a clear advance and settlement calendar
The workflow builds three-month periods and deadlines, applies both estimation methods, separates declared from paid amounts and reconciles advances to final tax.
Seventh practical workflow available
Start review and objectionSeparate review, objection and court routes, and understand penalty boundaries
The workflow starts deadlines from the correct event, calculates filing fees per decision and shows fine and settlement boundaries without deciding that a breach or offence occurred.
44 Articles explained
Read the Law Article by ArticleUnderstand the Decree-Law Article by Article — beyond a source link
Every Article has a separate page explaining the provision, Madar's plain-language commentary, audience, practical action, an illustration where useful, common pitfalls and connected official sources.
93 Articles across 9 chapters
Read the Regulations Article by ArticleUnderstand the Regulations and connect procedure to Law and guidance
The map covers both issuing Articles and every Regulations Article, with a verified summary, plain explanation, practical action, common pitfall and connected Law and official guidance.
Verified official sources
Current legal package
Legislation, Regulations, decisions and guidance are separated because each performs a different function and none replaces another.
Decree-Law
Tax on Multinational Enterprises
The primary legislation for scope, computation, registration, filing, payment, review, objections and penalties.
Open official sourceExecutive Regulations
DMTT Executive Regulations
Detailed rules on the revenue test, entities, computation, safe harbours, procedures and deadlines.
Open official sourceMinisterial Decision
Tax Objections Committee
Establishes the committee that considers objections submitted under Article 31 of the Decree-Law.
Open official sourceOfficial portal
Law, Regulations and FAQs
The official monitoring point for legislative, procedural and practical updates.
Open official sourceMinisterial Decision
Designation of judicial enforcement officers
Article 2 designates the listed officers for DMTT offences within their assigned jurisdictions. Published in Official Gazette 3899 on 13 August 2026.
Open official sourceEight published official guides
Guidance supporting the explanations and examples
The Law and Regulations are not enough on their own; current guidance covers the user journey from scope to return filing.
01
Scope of the Law and registration requirements
02Entities within the scope of DMTT
03DMTT registration manual
04DMTT administrative procedures
05Advance payment manual
06DMTT transfer pricing guide
07DMTT computation guideVersion 1.0 · updated 23 August 2026
08DMTT return filing manualVersion 1.1 · August 2026
Practical coverage map
Seven workflows covering the practical journey
Explore the Law and Regulations commentary and seven practical workflows: scope and registration, zero-tax, annual filing, computation, transfer pricing, payments and settlement, and review, objections and penalties. Read each explanation with the official text and the conditions of your case.
Workstream 1
Group scope and revenue test
Is the group multinational, does it meet the revenue test, and which fiscal years enter that test?
Covered by the scope and registration workflowWorkstream 2
Bahrain entities and exclusions
Identify Bahrain constituent entities, excluded entities and the effect of ownership and financial-statement structure.
Covered by the scope and registration workflowWorkstream 3
Registration and filing entity
Who registers, who is appointed as the filing constituent entity, and how are group changes reported?
Covered by the scope and registration workflowWorkstream 4
Tax base and computation
Move from accounting net income or loss to adjusted income, covered taxes and the effective tax rate.
Covered by the full-computation workflowWorkstream 5
Safe harbours and transfer pricing
Separate elective safe-harbour tests from transfer-pricing rules and evidence-based adjustments.
Covered by the zero-tax and transfer-pricing workflowsWorkstream 6
Payments, return and settlement
Organise advance payments, the final return, settlement and amendments while keeping each deadline distinct.
Covered by the annual filing and settlement workflowsWorkstream 7
Review, objections and penalties
Distinguish review from objection, including fees, deadlines, effects, penalties and offences.
Covered by the review, objection and penalties workflow