Reduces tax to zero for a limited period during the initial phase of international activity where the group operates in no more than six jurisdictions, has no more than EUR 50m of tangible assets outside the reference jurisdiction and meets the remaining conditions.
What should you do now?Identify the first in-scope year, reference jurisdiction, number of jurisdictions, asset value and ownership before claiming the exclusion.
What does the official Article provide?
The official source is Arabic. This English commentary is explanatory and is not presented as an official translation.
Reduces tax to zero for a limited period during the initial phase of international activity where the group operates in no more than six jurisdictions, has no more than EUR 50m of tangible assets outside the reference jurisdiction and meets the remaining conditions.
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.
What does the Article mean in plain language?
The exclusion is not based on company age alone; it tests geographic spread, tangible assets and IIR ownership, and ends five years after the group first enters the global rules.
Tax, accounting, reporting and transfer-pricing teams in large groups.
Identify the first in-scope year, reference jurisdiction, number of jurisdictions, asset value and ownership before claiming the exclusion.
Treating any new expansion or newly formed company as automatically in the initial phase.
Related Articles
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.