Executive summary

Bahrain's National Bureau for Revenue (NBR) has issued the Domestic Minimum Top-up Tax (DMTT) Return Filing Manual Version 1.0 (Manual), providing practical guidance on the DMTT return filing process, including payment and reporting of DMTT liability, submission obligations, refund procedures, navigation of the NBR online portal and questionnaires designed to determine revenue threshold eligibility and compliance requirements.

The Manual supports the implementation of Bahrain's DMTT regime introduced through Decree-Law No. (11) of 2024 and provides guidance on the annual filing obligations applicable to in-scope multinational enterprise groups (MNE Groups) subject to the Organisation for Economic Co-operation and Development (OECD) Pillar Two global minimum tax framework.

The Manual outlines the requirements for submitting a Revenue Test Notification and DMTT Tax Return, including rules relating to central filing, information reporting and DMTT tax computations.

The Manual provides worked examples, including a de minimis exclusion case reducing top-up tax to zero.

Background

Bahrain introduced DMTT through Decree-Law No. (11) of 2024, together with the related Executive Regulations, as part of its implementation of the OECD Pillar Two global minimum tax framework. The DMTT applies to in-scope MNE Groups with fiscal years beginning on or after 1 January 2025, and seeks to ensure that qualifying MNE Groups are subject to a minimum effective tax rate of 15%.

Following the release of various DMTT guidance documents, computation guide and FAQs, the NBR has now published the DMTT Return Filing Manual to support taxpayers with the annual DMTT return filing process through the NBR online portal. The Manual is intended to provide general guidance and should be read alongside the DMTT Law, its Executive Regulations and the OECD Pillar Two guidance. (For details on transfer pricing guidance related to the DMTT framework, see EY Global Tax Alert, Bahrain issues domestic minimum top-up tax transfer pricing guide, dated 15 June 2026.)

Key provisions

Revenue Test Notification

The Manual requires every Filing Constituent Entity (FCE) to submit a Revenue Test Notification for each Reporting Fiscal Year for which it is registered. The notification is designed to determine whether the MNE Group satisfies the €750m revenue threshold in at least two of the four fiscal years immediately preceding the reporting fiscal year.

If the Revenue Test Notification confirms that the group is not within the scope of DMTT, the FCE may elect not to submit a DMTT Tax Return for that year. Any advance payments previously made may be carried forward as DMTT credits, refunded upon request or offset against future DMTT liabilities and administrative fines.

DMTT Tax Return

For in-scope groups, the FCE must submit a DMTT Tax Return comprising the following three sections.

Central Filing Notification

The Central Filing Notification enables a FCE to notify the NBR that the Information Schedule will be filed in another jurisdiction that has a Qualifying Competent Authority Agreement with Bahrain. If this option is elected, the Information Schedule does not need to be filed in Bahrain, as long as the relevant Global Anti-Base Erosion (GloBE) Information Return (GIR) is filed centrally in another jurisdiction and is exchanged with Bahrain through the applicable information exchange mechanisms.

If the NBR does not receive the GIR within three months after the DMTT Return filing deadline, the obligation to complete the Information Schedule in Bahrain will be reinstated.

Information Schedule

If central filing is not elected, taxpayers must submit an Information Schedule containing information relating to constituent entities, joint ventures and joint venture subsidiaries, including entities located in Bahrain.

Taxpayers must prepare and file the Information Schedule in XML format and comply with the OECD GIR XML Schema requirements. If the FCE faces technical issues while generating the XML file, the NBR may, upon request, allow the FCE to manually populate the Information Schedule through the input form available on the portal.

Tax Computation Schedule

The Tax Computation Schedule replicates the charging mechanism for DMTT liabilities in

Bahrain. FCEs must report the Bahrain DMTT liability for all relevant sub-groups, including constituent entities, joint ventures, stateless entities, investment entities and minority-owned constituent entities, as applicable.

The final DMTT liability is calculated after considering annual Bahrain DMTT amounts reported for each sub-group, exclusions relating to liabilities attributable to other FCEs, advance payments made and available DMTT credits carried forward from prior periods.

Implications

The Manual provides the first detailed administrative guidance on Bahrain's annual DMTT return compliance requirements and offers greater visibility into the information and data expected by the NBR during the filing process. In-scope MNE Groups should assess their readiness for annual DMTT compliance by confirming their Filing Constituent Entity arrangements and registration status, determining whether central filing can be relied upon, assessing their ability to produce OECD-compliant GIR/XML files, evaluating the impact of any safe harbors or exclusions, and confirming that DMTT calculations, advance payment records and supporting documentation are maintained and reconciled ahead of the filing deadline.