Is your multinational group prepared for the 15% global minimum tax? We help you assess, plan, and comply.
The OECD's Pillar Two framework (GloBE Rules) establishes a global minimum effective tax rate of 15% for multinational enterprise (MNE) groups with consolidated revenue of EUR 750 million or more.
For Bahrain-based entities that are part of qualifying MNE groups, this means the 0% corporate tax environment may be supplemented by a top-up tax in either Bahrain (via a domestic minimum tax — QDMTT) or in the parent jurisdiction (via IIR/UTPR).
Bahrain is expected to introduce a Domestic Minimum Top-up Tax (DMTT) to retain taxing rights rather than cede them to other jurisdictions.
Global Minimum Rate
Revenue Threshold
Countries Agreed
Expected GCC Implementation
If your Bahraini entities have an effective tax rate below 15%, a top-up tax may be imposed either in Bahrain (DMTT) or by the parent jurisdiction.
Entities with real substance (payroll + tangible assets) can reduce their top-up tax through the substance-based income exclusion (SBIE).
Some holding, IP, and treasury structures may need redesigning. This creates planning opportunities alongside compliance requirements.
Determine if your group meets the EUR 750M threshold and model the potential top-up tax for each jurisdiction.
Calculate effective tax rates under GloBE rules, identify timing differences, and apply SBIE carve-outs.
Redesign holding, treasury, and IP structures to maximize SBIE and minimize top-up tax exposure.
Prepare GloBE Information Returns, establish data collection processes, and ensure ongoing compliance readiness.
Don't wait for implementation. Start your Pillar Two impact assessment today.
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