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July 13, 2026
Article 41 introduces General Anti-Abuse Rules (GAAR) to prevent tax avoidance under the Bahrain DMTT. The National Bureau for Revenue has the authority to disregard any transaction or arrangement that lacks a genuine commercial purpose or whose primary objective is to obtain an unfair tax advantage. In such cases, the Bureau can make 'just and reasonable adjustments' to determine the actual tax liability. The Executive Regulations will further define the rules and conditions for applying these anti-abuse provisions, ensuring they remain consistent with the OECD Pillar Two Model Rules and international standards for preventing base erosion and profit shifting.
Chapter 7 - Final Provisions
Article 41 - General Anti-Abuse Rules
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