Reviewed against the Decree-Law and official sources

Tax computation and safe harbours

Article 12 — De minimis exclusion

Sets tax to zero on an annual election where three-year average revenue is below EUR 10m and average income is below EUR 1m or a loss, subject to special rules.

Short answer

Sets tax to zero on an annual election where three-year average revenue is below EUR 10m and average income is below EUR 1m or a loss, subject to special rules.

What should you do now?Compute the current and two preceding-year averages, separate stateless and investment entities and document the annual election.

Provision in brief

What does the official Article provide?

The official source is Arabic. This English commentary is explanatory and is not presented as an official translation.

Sets tax to zero on an annual election where three-year average revenue is below EUR 10m and average income is below EUR 1m or a loss, subject to special rules.

This is a verified summary, not a substitute quotation. The complete official Arabic text is linked below and must be read with the Regulations and later decisions for a final decision.

Madar explanation

What does the Article mean in plain language?

This exclusion can apply even though the group met EUR 750m globally: the first test concerns group scope, while this one concerns the local three-year average.

Who should read this?

Tax, accounting, reporting and transfer-pricing teams in large groups.

Practical action

Compute the current and two preceding-year averages, separate stateless and investment entities and document the annual election.

Common mistake to avoid

Testing one year only or treating the exclusion as automatic without an election.

Complete picture

Related Articles

Limits of the commentary

Before relying on the result

Is the Article enough on its own?

Usually not. The Decree-Law states the rule, the Regulations detail the computation or procedure and guidance explains application. Use all three for an obligation, amount or deadline.

Are OECD materials binding by themselves?

Not every international document is Bahrain legislation by itself. It is used within the Law's referrals or a competent adoption instrument, while current Bahrain legislation and decisions remain controlling.

References

Official sources