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Article 42 provides transitional provisions for MNEs moving into the Bahrain DMTT regime. It requires Filing Constituent Entities to account for deferred tax assets and liabilities disclosed in their financial accounts to determine the Effective Tax Rate during the transition year. However, deferred tax assets related to items excluded under Article 6 or transactions occurring after 30 November 2021 are subject to specific exclusion or carrying value rules. Assets transferred between group members after this date but before the transition year must use the transferring entity's carrying value. These rules ensure a consistent accounting baseline in line with OECD Pillar Two standards.
Chapter 7 - Final Provisions
Article 42 - Transitional Provisions
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