Article commentary and official references

Accounting

Article 27 — International shipping income exclusion

Excludes international shipping and qualified ancillary income where strategic or commercial ship management is effectively carried out in Bahrain, subject to defined limits.

Short answer

Excludes international shipping and qualified ancillary income where strategic or commercial ship management is effectively carried out in Bahrain, subject to defined limits.

What should you do now?Document ship management, income and expense streams and the limit for qualifying ancillary income.

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.

Excludes international shipping and qualified ancillary income where strategic or commercial ship management is effectively carried out in Bahrain, subject to defined limits.

This is a verified summary rather than a verbatim reproduction. Consult the official Arabic text, the Law and later decisions before making a final determination.

Madar explanation

What does the Article mean in plain language?

The exclusion requires evidence that strategic or commercial management of all relevant ships is effectively conducted from Bahrain. Use the qualifying activity list; inland-waterway transport within Bahrain is excluded from that list. Qualifying losses are also removed. Aggregate qualifying ancillary income is capped at 50% of Bahrain entities' aggregate international shipping income, with activity-specific conditions. Allocate direct costs to the activity and indirect costs by revenue proportion before calculating the excluded net result.

Who should read this?

Financial reporting, tax, transfer-pricing and consolidation teams.

Practical action

Document ship management, income and expense streams and the limit for qualifying ancillary income.

Common mistake to avoid

Excluding all maritime revenue or applying the cap to gross revenue instead of the defined net income.

Legislative connection

Related Articles

Limits of the commentary

Before relying on the result

Is this Article enough on its own?

Usually not. Read it with the connected Law Article, definitions, any effective election and current NBR guidance, especially for an amount or deadline.

Does NBR guidance replace the Regulations?

No. Guidance explains application and supports procedures and examples, but current legislation and decisions prevail in case of inconsistency.

References

Official sources