Optimize your group structure for tax efficiency across jurisdictions.
Bahrain holding company — no withholding tax on dividends. DTA access for treaty-eligible income. No capital gains on share disposals. Exempt from DMTT if purely domestic.
Management fee structuring — arm's length pricing. Shared service centre in Bahrain — cost allocation. IP licensing arrangements — transfer pricing documentation. Treasury centres — interest deductibility.
Eliminate VAT on intra-group transactions. Single VAT return for the group. Joint and several liability — risk assessment. Entry/exit planning for group members.
Entity rationalization — reduce number of entities. Substance enhancement — align profits with operations. QDMTT election — keep top-up tax in Bahrain. CbCR alignment with DMTT computations.
