Connect with us

Financial

With DMTT coming into effect on Jan 1st, 2025, a tax expert explains everything businesses in Bahrain need to know

Published

on

DMTT

Last September, the Kingdom of Bahrain introduced a new law to implement a Domestic Minimum Top-up Tax (DMTT) at a rate of 15% on businesses operating in the Kingdom that meet certain criteria.

With the tax coming into effect in time for the new year, Mr. Nilesh Ashar, an international tax specialist with more than 25 years of experience, serving as Senior Managing Director & Head of Tax Middle East at FTI Consulting, provided a comprehensive overview of the new law and its implications for businesses in Bahrain.

Mr. Ashar stated that the Kingdom’s decision is a significant milestone in the Middle East, with Bahrain emerging as a front runner to implement the DMTT on large multinational enterprises (MNEs) having presence in the Kingdom.

“The new law underscores Bahrain’s international commitment as part of the inclusive framework of the Organization for Economic Cooperation and Development (OECD), to address base erosion and profit shifting by MNEs,” stated Mr. Ashar.

“Effective January 1st, 2025, onwards, the law is largely based on the OECD Model Rules on global minimum tax (GMT) in terms of calculation of the tax, exclusions, and reliefs. Additionally, the new law contains specific provisions on procedures, enforcement, and anti-avoidance measures applicable in the Kingdom.”

While explaining who will be affected by this tax, and what the law actually entails, he added that the new law applies a 15% tax on the income of Bahrain entities (including permanent establishment, joint venture, and JV subsidiaries) that are part of an MNE group with annual consolidated revenue exceeding €750 million, for at least two out of four preceding fiscal years. However, the tax does not apply to foreign subsidiaries of a Bahraini-headquartered group or other foreign group companies that are part of the same MNE group. The DMTT is also not applicable to certain excluded entities as specified in the law, including government bodies, international organizations, non-profit organizations, sovereign wealth funds, pension funds, and certain investment funds.

Mr. Ashar explained that the law lists specific transitional and permanent reliefs from the levy of DMTT, including transitional country-by-country safe harbor relief, exclusion for the initial phase of international activity, de-minimis exclusion, and simplified computation safe harbor relief.

Describing key considerations for businesses, Mr. Ashar said that, since the law is effective from January 1st, 2025, and detailed rules (Executive Regulations) are expected to be published in the coming months, it is now imperative for businesses to assess the impact of the DMTT on their Bahrain presence, evaluate the availability of any reliefs, and prepare for the compliances to be undertaken based on the law read in conjunction with the OECD Model Rules.

Mr. Ashar described, “In terms of taxable income, this is defined in the law as the financial accounting net income or loss for the fiscal year, before making any consolidation adjustments eliminating intra-group transactions, in accordance with the local accounting standards. Detailed rules on calculation of taxable income will be prescribed in line with the OECD Model Rules. Several compliance obligations are specified in the law including obtaining a registration, filing of annual tax returns, and paying taxes in advance over the relevant fiscal year. These compliances are expected to be in addition to the notifications and filings as required by the MNE Group under the OECD Model Rules.”

In addition, the law also provides specific provisions on enforcement via conduct of tax audits, assessments and procedures in relation to litigation and appeals. Mr. Ashar noted that a Tax Objection Committee will be formed for this purpose. Also, penal consequences are laid out in case of defaults, like failure to obtain registration, file tax returns, or submitting incorrect data. Such defaults may trigger stringent administrative fines, without prejudice to criminal liability.

Mr. Ashar further explained that a general anti-avoidance rule empowers the National Bureau of Revenue to disregard any transaction if it is not genuine or its primary purpose is to obtain a tax advantage against the objective of the law. Furthermore, the law specifies certain acts to qualify as ‘tax evasion,’ resulting in onerous consequences including criminal liability for legal persons, if held responsible for such evasion. Dispute resolution through a settlement process is acknowledged.

Mr. Ashar concluded that the Executive Regulations to the law are yet to be issued and are expected to prescribe detailed rules, controls and manner of calculation and application of DMTT in a manner consistent with the Model Rules. He also noted that since the law is published in the Arabic language, his views are based on an unofficial translation of the law.

Continue Reading
Click to comment

Leave a Reply

Your email address will not be published. Required fields are marked *

Financial

ENOVATE AND COBI LAUNCH LARGE-SCALE AI-POWERED DIGITAL PAYMENT INFRASTRUCTURE

Published

on

eNovate, a subsidiary of eFinance Investment Group, and Cobi, a UAE-headquartered AI-native customer intelligence platform, today announced the integration of Cobi’s AI-powered intelligence infrastructure across its digital payment ecosystem to redefine how young people across Egypt engage with digital financial services. Enabled through Mastercard’s Engage programme, the partnership combines eNovate’s digital payments product suite and Cobi’s AI-powered engagement platform to give financial institutions a new level of intelligence, personalisation, and behavioural insight across their customer base. As the MENA region emerged as a global hub for financial services innovation in 2025, fuelled by government initiatives and rapid digital payments growth, the focus is shifting toward AI-powered engagement and intelligence at scale.

The collaboration begins with the Rize app, eNovate’s flagship digital wallet, where Cobi’s intelligence layer will power real-time personalisation for Egypt’s youth segment. With 85% of people across MENA already using at least one emerging payment method, this allows banks and fintechs to better understand spending behaviours, identify friction, and deliver timely product interventions that drive activation, loyalty, and long-term customer value. The capability will extend across eNovate’s broader digital payment services, forming Egypt’s first large-scale AI-driven portfolio management infrastructure.

With the MENA region’s AI in financial services market projected to reach $4.7 billion by 2032, underscoring the scale of opportunity for intelligent, data-driven payment infrastructure across the region. At the core of the partnership is Cobi’s behavioural AI engine, which builds deep context on how users engage, identifies patterns, and recommends or triggers next-best-actions across acquisition, activation, and retention journeys for customers combining it with eNovate’s role as a central payments and digital services provider to Egypt’s banks, telcos, fintechs, merchants, and government-linked entities, the collaboration marks a major step toward intelligent, personalised financial experiences across the country.

Nashwa Kamel, CEO of eNovate, explained: “eNovate is committed to enabling banks & financial institutions with modern, data-driven capabilities. Partnering with Cobi allows us to introduce real-time intelligence into every digital wallet and payment experience we support, starting with the youth-focused Rize app. This collaboration strengthens our mission to provide Egypt with the most advanced and responsive payment infrastructure that provides insights into spend behaviour, helping banks & financial institutions to spot inefficiencies, optimize costs, and make smarter, data-driven decisions. By turning raw spend data into strategic intelligence, businesses can anticipate trends, strengthen supplier relationships, and accelerate sustainable growth.

Darren Edmund, CEO of Cobi, highlighted: “Our partnership with eNovate represents a fundamental shift in how digital payment infrastructure operates. By embedding Cobi as the intelligence layer across eNovate’s ecosystem, we are enabling banks and financial platforms to move beyond static transaction processing toward real-time, adaptive systems that understand and respond to user behaviour instantly. This allows institutions to personalise at scale, optimise portfolio performance, and build deeper, longer-lasting customer relationships. We’re glad to have had Mastercard’s Engage programme support this collaboration.”

Looking ahead, the partnership will extend toward agentic payment experiences, where AI not only analyses user behaviour but autonomously recommends or initiates actions that improve financial outcomes, ushering in a new era of intelligent and proactive financial services across Egypt. The initial deployment begins in Q1 2026, with expansion planned across additional eNovate-powered platforms and regional markets.

Continue Reading

Financial

UAE ATTRACTS $40BN IN FDI AMID GLOBAL UNCERTAINTY, NEW REPORT SUPPORTED BY QASHIO REVEALS

Published

on

As geopolitical tensions, de-globalisation, and economic uncertainty reshape global capital flows, the United Arab Emirates (UAE) is consolidating its position as one of the world’s most trusted and resilient financial gateways, according to a new report by Emerging Markets Intelligence & Research (EMIR), supported by Qashio.

The report, ‘Mapping the UAE’s Role as a Global Financial Gateway’, highlights how the UAE is attracting high levels of foreign direct investment and financial activity at a time when capital is retreating from many traditional markets.

Foreign direct investment into the UAE doubled to $40 billion (between 2019 and 2024), reaching record levels even as global FDI stagnated. In 2024, FDI accounted for 40% of the UAE’s gross capital formation, compared to just 4.3% across developed economies, underscoring the country’s growing role as a destination for long-term, trust-led capital.

The scale of activity is accelerating rapidly. The UAE recorded 1,362 FDI projects in 2024, representing a 350% increase since 2020, while assets under management in the Dubai International Financial Centre (DIFC) reached $700 billion, growing 58% year-on-year.

According to the report, the UAE’s ability to benefit from global realignment is closely linked to its neutrality, regulatory clarity, and institutional agility.

“The UAE is actually benefiting from the de-globalisation and the geopolitical reorientation of major power blocks. It doesn’t have adversaries, so is able to build economic ties with everyone. The speed with which the government has been able to adapt to and anticipate the new situation is remarkable,” the report notes.

Beyond capital inflows, the research also points to the UAE’s expanding role as a transaction and payments hub, supported by modern financial infrastructure, strong compliance frameworks, and growing confidence among global businesses managing cross-border activity from the region.

From Qashio’s perspective, the UAE’s rise as a financial gateway reinforces the importance of secure, transparent, and compliant financial operations for businesses operating in an increasingly complex global environment.

“As capital flows become more fragmented and regulated, trust and control are no longer optional — they are foundational,” said Armin Moradi, Founder and CEO of Qashio. “Businesses operating from the UAE need full visibility over spending, strong compliance with Central Bank guidance, and the ability to act on financial insights in real time. This report reflects why the UAE has earned global confidence — and how organisations can operate responsibly within that ecosystem.”

The findings position the UAE not only as a safe destination for capital, but as a jurisdiction capable of supporting long-term growth across finance, trade, technology, and digital assets — at a time when global businesses are reassessing where and how they deploy resources.

To learn more about how the UAE is consolidating its role as a trusted global financial gateway and what this means for businesses navigating today’s fragmented capital landscape download the full report here.

Continue Reading

Financial

THE STARTUP QUESTION: WHY MOST AI INVESTMENTS ARE AUTOMATING 2016 INEFFICIENCY

Published

on

A robotic hand reaching toward a human hand on a dark background, with the words “Automate Everything” and the letters “A” and “I” highlighted in red above them, representing AI innovation from Deriv.

By Rakshit Choudhary, CEO, Deriv

The first weeks of 2026 have made one thing clear. AI is no longer moving in steps, it is moving in leaps. Across the Middle East and globally, organisations are spending hundreds of billions on AI, yet most will fail to see a lasting advantage. This isn’t a technology failure, it’s an architectural one. They are using 2026 intelligence to automate 2016 processes that shouldn’t exist in the first place.

One question separates genuine transformation from expensive automation. If you were building this business from scratch today, how would you design it?

 The asymmetry of the legacy burden

Established companies face a challenge startups do not. Every advantage built over time eventually hardens into a constraint. Processes reflect historical decisions made years ago, and systems are optimised for legacy technology.

A startup building your business today wouldn’t carry your infrastructure or justify changes to existing teams; they would simply build what makes sense now. This creates a painful reality where startups move faster not because they are smarter, but because they don’t have to preserve a museum.

At Deriv, we faced this asymmetry head-on. We had to redesign our entire foundation while maintaining over $650 billion in monthly trading volume for 3 million clients. It is the equivalent of building a new aeroplane while flying at 35,000 feet.

Designing for intelligence, not compensating for its absence

Most organisations approach AI by asking, “What can AI do for us?”. That is the wrong question. It leads to incrementalism, existing workflows executed slightly faster.

When we applied “startup thinking” to Deriv, we stopped treating AI as a tool and started treating it as a design constraint:

  • Customer service: The answer wasn’t faster scripts, but an AI agent with direct system access. Our agent, Amy, now handles 79% of customer chats globally with 97% satisfaction.
  • Engineering: We didn’t just ask for more “copilots.” We built for AI-generated code with built-in quality controls. Today, over 50% of our code is AI-generated, putting us ahead of most software firms in a regulated environment.

Every time we asked the “startup question,” we discovered that legacy processes were designed around constraints that no longer existed. Technology limitations from a decade ago or organisational structures reflecting a much smaller company.

The investment that actually matters: Readiness

AI capability is no longer the bottleneck. Access to breakthroughs is now commoditised and available across markets as quickly as it emerges. The real constraint is organisational readiness.

The most valuable investment we made in 2025 wasn’t software, it was people. We have hired over 100 AI engineers to build AI-native operations, but we also upskilled our existing global workforce. This wasn’t about teaching them to use a chatbot, it was about changing their AI literacy so they instinctively ask if a process should exist at all.

The widening gap

We are at a critical inflection point. Product lifecycles and release timelines that took months now happen in weeks. Companies that redesign workflows for autonomous systems will benefit automatically as AI improves. New capabilities will integrate without disruption.

Conversely, those automating legacy processes will find themselves trapped in a cycle of continuous, expensive rebuilding. By mid-2026, this gap will become permanent.

The startup question isn’t comfortable. It challenges every inherited assumption. But for businesses operating in sophisticated, highly regulated markets, it is the only question that leads to growth rather than mere efficiency.

The time to ask the startup question is now.

Continue Reading

Trending

Copyright © 2023 | The Integrator