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

A VAT objection against a decision, procedure or dispute with the NBR must be filed with the Committee within 30 days of notification. 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. Under Decision No. 33 of 2020, the fee is BHD 50 for each disputed decision or procedure. The Committee recommends within 30 days, the Minister or delegate decides within 15 days, and court challenge is available within 60 days; collection is not suspended.

Who should read this?

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

Why does it matter?

A tax objection has its own subject, deadline, fee and admissibility conditions, distinct from assessment review and a penalty grievance.

30 daysBHD 50 per decision or procedureCollection continues
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

Upon the issue of a decision by the Minister or his authorised delegate, a committee named the “The Tax Appeals Review Committee” shall be formed with a head, whose grade is not less than director at the Bureau, and at least five other members with experience in tax, finance, accounting and legal matters. The Committee, in addition to its competence set forth in Article 62 of this Law, shall examine and consider all objections and all disputes between Taxable Persons and the Bureau with regard to Tax. The Taxable Person shall submit an objection to the committee within thirty days from the date of notification of the decision or procedure subject to paying the prescribed fee. The committee shall issue its recommendation with regard to the objection within thirty days from the date of submission thereof and submit it to the Minister or his authorised delegate, provided the Minister or his authorised delegate issues a decision to approve, amend or cancel such recommendation within fifteen days from the date of receipt. The applicant shall be notified of the final decision on his objection by the methods prescribed by law. Where no notice is issued in the prescribed period, this will constitute an implied rejection. The concerned party may appeal to the competent court against the decision of the Minister or his authorised delegate within sixty days from the date of notification of rejection or the date on which his objection was rejected. An appeal against the decision shall not prevent the competent court from collecting Tax due. The Regulations shall specify the order and procedures of the committee and the controls for holding its meetings.

Application steps

  1. 1

    List each challenged decision or procedure.

  2. 2

    Record sending date and count from the next day.

  3. 3

    Apply Decision 33's BHD 50 fee per decision or procedure.

  4. 4

    Meet tax-payment and Article 95 requirements.

  5. 5

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

Connected provisions

Official guides and tools

Connected Madar tools

Illustrative example by Madar

One notice covering two decisions

If notice was sent on 1 August, counting starts on 2 August. Where two distinct decisions are objected to, test a separate BHD 50 fee for each under Decision No. 33 of 2020.

Questions to help you apply it

  • Is this a tax objection or a penalty grievance?
  • How many decisions are challenged?
  • Are the deadline, fee and payment conditions met?