Government Proposes Changes to the Domestic Minimum Top-Up Tax Act, 2024
02/06/26
Update from the Department of Inland Revenue - One Tax Bahamas DMTT Registration Portal Opens
One Tax Bahamas DMTT Registration Portal Opens
The Department of Inland Revenue has opened the One Tax Bahamas portal for Domestic Minimum Top-Up Tax (DMTT) Registration, filing and payment. Entities in scope of the Act will be required to take the following steps:
Step 1: Register for a Bahamas Identification Number (BIN)
All constituent entities must register for a Bahamas Identification Number (BIN) on One Tax Bahamas. This BIN serves as an official identifier connecting all of the entity’s information, transactions, and activities across all tax-related services on the platform.
Constituent entities who currently have a Tax Identification Number will receive an email to their OTAS contact email from mailto:OTBINFO@bahamas.gov.bs to commence the BIN registration process.
Step 2: Appointment of a Tax Representative
All DMTT fillings must be filed by a tax representative. The representative must be a Public Accounting Firm Licensed by the Bahamas Institute of Chartered Accountants (BICA).
Step 3: Register for DMTT
Once an approved BIN has been received and a tax representative appointed, each constituent entity will be required to register in the portal for DMTT.
Step 4: File DMTT Return
Constituent entities in The Bahamas are required to file a DMTT Return or a GloBE Information Return even there’s no DMTT liability. The Return is due within 18 months after the fiscal year for the Transition Year and 15 months thereafter. For fiscal years ended 31 December 2024, the Department of Inland Revenue has extended the filing deadline to 30 September 2026.
No extension has been provided for payment obligations. Payment is due in Bahamian dollars or United States dollars by 30 June 2026.
Penalties
Failure to comply with the filing and payment requirements under the Domestic Minimum Top-Up Tax Act, 2024 may result in penalties, interest, and other civil compliance actions.
On 27 May 2026, during its budget communication, the Government of The Bahamas introduced the Domestic Minimum Top-up Tax (Amendment) Bill, 2026. This bill proposes updates to the Domestic Minimum Top-Up Tax (DMTT) Act, 2024, including:
Expanded Filing Requirements
Constituent entities covered within the scope of the Act must file either a GloBE Information Return or a prescribed return, even if no tax is due. For entities which are dual-resident in The Bahamas and another jurisdiction, a Constituent entity must inform the authorities and provide supporting documentation that they are located in the other jurisdiction.
Payment Currency
All DMTT liabilities, including taxes, penalties, and interest, must be paid in Bahamian dollars or US dollars.
Introduction of Instalment Payment Regime
Constituent entities liable for DMTT must make instalment payments at specified intervals based on the previous fiscal year’s DMTT amount. Penalties will be assessed for underpayment.
Changes to Advance Rulings
Advance rulings issued by the Secretary will be valid for a specified period and will become void if they conflict with the OECD GloBE Rules or later guidance.
How can we help?
Please reach out to our tax team to discuss the impact of these changes.
DMTT Registration and Filling Updates
(05/05/2026)
The Department of Inland Revenue (DIR) announced key updates on the registration and filing
timelines for constituent entities within multinational enterprise (MNE) groups thatt are subject to The Bahamas Domestic Minimum Top-Up Tax Act, 2024 (DMTT Act).
One Tax Bahamas – The Bahamas’ new tax portal will require entities to register for a Bahamas Identification Number (BIN). Registration for a BIN number began on 1 May 2026 and can be completed by the entities Tax Representative.
The Registration, Filing and Payment Portal for DMTT will be available from 1 June 2026. Before submission, a licensee from BICA (The Bahamas Institute of Chartered Accountants) must review the DMTT Return. For entities with fiscal years ending on 31 December 2024, the deadline for filing and payment under the scope of the DMTT Act is 30 June 2026.
Contact
Should you have any questions, please do not hesitate to contact us.
Overview
The Bahamas introduced the Domestic Minimum Top-Up Tax Act, 2024 in November 2024. All constituent entities in The Bahamas who are within the scope of this Act are required to file a “DMTT Notification Form” by 31 March 2026.
Subsequent to the filing of the notification form, entities will be required to register on The Bahamas’ new “One Bahamas” tax portal which is expected to open in the second quarter of 2026. The first filing and payment requirements in The Bahamas for entities who were in scope from 1 January 2024, will be due 30 June 2026 within the “One Bahamas” tax portal.
Who is required to submit a notification form?
Domestic members of a MNE Group whose consolidated financial statements have total revenues exceeding €750 million in at least two of the four tax years preceding the tested year. This includes all entities incorporated in The Bahamas and permanent establishments in The Bahamas of the MNE Group.
Contents of the notification
The notification must be submitted using the prescribed form on the DIR’s website. The form requires the following to be included:
- Details of the local entity or permanent establishment;
- Details of the MNE Group including annual revenue;
- Information surrounding the MNE Group’s Country by Country Reporting status;
- Details of the Ultimate Parent Entity including total revenue;
- Details of the reporting entity.
How can we assist you?
The deadline for notification is rapidly approaching, and prompt action is necessary to ensure all data required for filing is readily accessible. Our team is available to support your notification needs. Please contact our tax department below for further information.
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