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 transitional provision addressed invoices or payments before VAT commencement or registration where actual Supply occurred afterwards. It is a historical transition rule, not a substitute for the ordinary current time-of-Supply rules.

Who should read this?

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

Why does it matter?

This transitional rule is not a replacement for ordinary current time-of-supply rules.

TransitionalHistoric factsNot a current deadline

Current text

If an invoice has been issued or the Consideration for the Goods and Services has been paid before the effective date of this Law or before the date of registration, and the Supply has been made after that date, the Supplier of the Goods or Services is considered to have made a taxable Supply on the date of actual supply of the Goods or Services. In this case, the Taxable Person shall issue a Tax Invoice which includes the Tax due for the Supply of the Goods or Services, unless an invoice issued prior to the date of the Law coming into force included the value of the Tax due. For the purposes of applying this Article, the date of Supply shall be considered to be after the date of the Law coming into force in the following two cases: If the date of delivery of the Goods is later than the date of the Law coming into force. If the date the Service was completed is later than the date of the Law coming into force.

Application steps

  1. 1

    Record invoice, payment and actual performance dates.

  2. 2

    Establish the connection to commencement or registration.

  3. 3

    Use ordinary timing rules for a current non-transitional transaction.

Connected provisions

Direct legislative link

Regulations — Article (107)

Related Regulations Article (107)

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

Open connected Article

Official guides and tools

Official text

Value Added Tax Law

Article (75)

Official guide

VAT General Guide

Practical guidance relevant to the Article

Illustrative example by Madar

Invoice before 2019, performance after

The transitional rule may follow the later delivery or completion date, but it does not replace the ordinary tax-point rules for a current transaction.

Questions to help you apply it

  • Is the event genuinely transitional?
  • When was the supply actually performed?