In brief
In June, the National Bureau for Revenue (“NBR”) of Bahrain issued its first Transfer Pricing Guide under the Domestic Minimum Top-Up Tax (“DMTT”) framework, providing further guidance on Transfer Pricing for Multinational Enterprise (“MNE”) groups that fall within the scope of the Bahrain DMTT Law and its Executive Regulations.
The guide builds on Article 13 of the Bahrain DMTT Law which sets out requirements in relation to the arm’s length principles and transfer pricing documentation requirements. It is broadly aligned with the Organisation of Economic Co-operation and Development (“OECD”) Transfer Pricing Guidelines and refers to Guidelines for further guidance on applying the concepts and mechanisms of the arm’s length principle.
This alert provides an overview of the key areas covered in the guide, the practical implications for in-scope businesses in Bahrain, and the steps MNE groups should consider as they prepare for compliance.
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Bahrain’s new Transfer Pricing Guidelines: Another steps towards DMTT implementation
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MNE Groups operating in Bahrain should plan ahead and prepare for the upcoming compliance requirements.
Our team is working on readiness, and implementation and compliance support, such as systems and process updates for a variety of businesses in the region in the context of the Pillar Two rules including DMTTs, and will be happy to support you. Please contact us for further assistance.
Jochem Rossel
Partner, Middle East Tax & Legal Services Leader, PwC Middle East
Steven Cawdron
Partner, Transfer Pricing, Tax & Legal Services, PwC Middle East
Richard Bregonje
Bahrain Corporate Tax Leader, PwC Middle East
Mohamed Al Mahroos
Partner, Bahrain Country Senior Partner, Government & Public Sector, Tax & Legal Services, PwC Middle East
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