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July 13, 2026
Article 2 outlines the primary objectives of Decree-Law No. 11 of 2024, focusing on the implementation of a global minimum tax rate for domestic top-up purposes. It ensures that Multinational Enterprise Groups in Bahrain are subject to a domestic top-up tax consistent with the OECD Pillar Two Model Rules. The Article emphasises establishing a safe harbour for qualified domestic top-up taxes to streamline compliance for MNEs. Furthermore, it mandates that any interpretation or application of this Law must take into account the guidelines, commentary, and rules issued by the OECD regarding base erosion and profit shifting (BEPS) to maintain international alignment.
Chapter 1 - Preliminary Provisions
Article 2 - Objectives of the Law
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