English text status

English translation published by the Legislation and Legal Opinion Commission. The Arabic text published in the Official Gazette remains the legal reference in the event of any discrepancy.

Practical summary

This is the grievance route for a decision imposing an administrative penalty. It must be filed within 30 days. The notification date is excluded, so day one is the following day; if the final day is an official holiday, time extends to the next working day. The Committee recommends within 30 days, the Minister or delegate decides within 15 days, and a court challenge is available within 60 days. Decision No. 33 of 2020 does not list a separate grievance filing fee, but Regulation Article (95) requires payment of the penalty under grievance for admissibility.

Who should read this?

Taxable Persons, finance teams and advisers applying this Article to a Bahrain VAT position.

Why does it matter?

A penalty grievance is distinct from an objection to VAT. No separate filing fee does not remove the fine-payment admissibility condition.

Administrative penalty30 daysNo separate filing fee
Before filing: name the route correctly

Penalty grievance ≠ tax objection

Grievance

Administrative-penalty decision

No separate filing fee

File within 30 days, counting from the day after notification, with an extension where the final day is an official holiday. Payment of the disputed penalty is an admissibility condition, not a filing fee.

Objection

VAT decision, procedure or dispute

BHD 50 per decision or procedure

File within 30 days, counting from the day after notification. If the final day is an official holiday, time extends to the next working day. Collection is not suspended.

Notification day excludedCommittee: 30 daysDecision: 15 daysCourt: 60 daysFinal-day holiday extends time
Official Decision No. 33 of 2020

Current text

A Person against whom a decision has been issued to impose an administrative fine may challenge it before the Tax Appeals Review Committee in accordance with Article 66 of this Law within the same periods and in accordance with the same rules and procedures prescribed for Tax Appeals. The Tax Appeals Review Committee shall issue its recommendation on the appeal within thirty days from its submission and shall submit its recommendation to the Minister or his authorised delegate. The Minister or his authorised delegate shall issue his decision to approve, amend or cancel the recommendation within fifteen days from the date its receipt. The appellant shall be notified of the final decision on the appeal request by the methods prescribed by law. If the period referred to ended without notice to the appellant, the decision shall be deemed to have been rejected. The appellant may appeal against this decision before the competent court within sixty days of the date of notification of rejection of his appeal or from the date his request was considered rejected.

Application steps

  1. 1

    Confirm that the challenged document imposes a fine.

  2. 2

    Record the sending date and exclude that day from the 30-day count.

  3. 3

    Submit within 30 days with Article 95 information.

  4. 4

    Distinguish payment of the fine from a filing fee.

  5. 5

    Move an official-holiday final day to the next working day.

Connected provisions

Direct legislative link

Regulations — Article (95)

Related Regulations Article (95)

This provision supplies the linked rule or procedure needed to apply the Article correctly.

Open connected Article
Direct legislative link

Regulations — Article (94)

Related Regulations Article (94)

This provision supplies an additional notification or deadline rule needed to apply the Article correctly.

Open connected Article
Direct legislative link

Regulations — Article (106)

Related Regulations Article (106)

This provision supplies an additional notification or deadline rule needed to apply the Article correctly.

Open connected Article

Official guides and tools

Official text

Value Added Tax Law

Article (62)

Official ministerial decision

Decision No. 33 of 2020

Objection fees; no separate grievance filing fee is listed

Connected Madar tools

Connected Madar tools

Breaches and Penalties Centre

Classify the exposure and preserve the correct response route.

Illustrative example by Madar

Notice sent on 1 August

The notification day is excluded, so 2 August is day one of the 30-day grievance period. If day 30 is an official holiday, the deadline moves to the next working day.

Questions to help you apply it

  • Does the dispute concern the fine or underlying VAT?
  • What is the evidenced sending date?
  • Has the required fine payment been made?