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

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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.

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RETHINKING THE FUTURE OF VENTURE CAPITAL IN AN AI-DRIVEN WORLD

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A person standing with arms crossed in front of a digital blue gradient background featuring the Hashgraph Ventures logo.

Dara Campbell, Senior Executive Officer, Hashgraph Ventures Manager

Venture capital isn’t what it used to be and that’s a good thing. The old playbook of “spray and pray,” waiting a decade for liquidity, and celebrating paper mark-ups is a thing of the past. In 2026, our industry is becoming faster, leaner, more intentional, and, ironically, deeply human.

We are standing at the intersection of the two most powerful technological waves of our generation: digital assets and artificial intelligence. This is not to say that these are the trending sectors for investment, but it is rather that funding the financial and digital infrastructure will define how value moves, how intelligence is deployed, and who ultimately owns the systems we will depend on.

We need to collectively acknowledge that programmable money and machine learning will be the drivers of the next generation of wealth. We are entering into an era where AI will help allocate, transact, and streamline capital in a faster and more efficient and adaptive way.

The most agile founders we see today are building with intent, efficiency, and transparency. They are building solutions in payments, logistics, supply chains, identity, and data ownership using real time AI infrastructure with blockchain rails underneath. When these two levels come together, you unlock productivity and scale in a way the traditional systems still can’t process.

Despite all this advancement, at its core venture capital remains a people-centric business. The biggest edge is access to conviction. When you meet a founder who can articulate why they are building something, not just what they are building, that’s where the signal lies. In my experience, the best investors will be those who can recognize that clarity early, match the founder’s passion, and stay in the trenches long after the initial cheque is written.

This is where the transformation is starting to show. As we move into 2026, we are also entering a new phase of infrastructure and DeFi 2.0. The dull layers – the rails, the protocols, the identity frameworks are becoming the foundation for this shift. From AI agents paying autonomously to real-world assets being tokenized at scale, these systems will underpin the next wave of innovation.

This is where Abu Dhabi is making strides on the global venture landscape. The emirate has rapidly emerged as a serious capital hub because it understands alignment. They are not replicating an ecosystem that’s been done before and has been successful – they are building something from the ground up that works for the region, for the new era of investors who are riding the wave of innovation.

The next generation of investors will be those who can successfully practice agility within the realm of regulation and who can integrate AI without compromising on the power of human instincts. The future of venture capital isn’t about replacing humans with machines; it’s about embedding systems in place where these two elements amplify each other. It’s a delicate balance, but that’s where the outliers are built.

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UAE MOVES TOWARDS A MORE COMPLIANCE-FOCUSED TAX LANDSCAPE WITH RECENT VAT REFORMS: DHRUVA

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Dhruva, a premier tax advisory firm with deep expertise across the Middle East, India, and Asia, stated that the UAE’s latest amendments to the VAT Law and the Tax Procedures Law, issued by the Federal Tax Authority (FTA) which are effective from 1 January 2026, represent a significant shift toward a more structured, and risk-focused tax environment. These amendments are expected to reinforce responsible compliance behaviors and reduce administrative friction for UAE businesses.

Dhruva noted that one of the most practical and welcoming changes is that it eliminates the requirement for taxpayers to self-issue tax invoices for imports subject to the reverse charge mechanism, which provides a lot of ease to businesses. Post series of amendments and clarifications issued by the FTA in 2025 in relation to self-issuance of tax invoices for imports, while a general exception was granted for such requirement for import of services, the same were required in case of import of goods for record-keeping purposes.  This often-added administrative complexity without impacting the actual tax liability or input tax entitlement. Under the updated rules, taxable businesses have removed the obligation entirely, and hence, businesses will only need to maintain standard supporting documentation, such as invoices, contracts, and transaction records.

However, the firm highlighted that while some administrative burdens are being eased, compliance expectations are tightening elsewhere.  One of the amendments gives the FTA authority to deny input tax recovery in cases linked to tax evasion – where a taxpayer knew or, critically, should have known, that a supply or its broader supply chain was connected to tax evasion.  The law clarifies that taxpayers will be deemed to have been aware if they fail to verify the validity and integrity of the supply in accordance with procedures to be issued by the FTA.

Dhruva explained that historically, the responsibility to account for VAT rested primarily with the supplier, and recipients focused mainly on validating the tax invoice and meeting standard input-tax recovery conditions. In practice, however, the FTA has often linked a recipient’s input-tax eligibility to the supplier’s discharge of output VAT, denying recovery where gaps existed. The latest amendment now formally embeds this position in law, imposing additional due-diligence obligations on the recipient.

Ujjwal Pawra, Partner at Dhruva Consultants, commented, “This is a significant change. It is a clear message that the right to input tax recovery comes with the responsibility to validate the integrity of one’s suppliers and supply chain. Businesses must now demonstrate that they exercised practical, documented, and consistent due diligence. Clean invoices alone are no longer enough; what matters is a clean process.”

While the procedures and conditions are awaited, Dhruva advised that companies reassess onboarding procedures, supplier-vetting protocols, and documentation trails to ensure they align with the FTA’s expected standards. 

Another material operational change is the introduction of a defined timeframe to act on credit balances. Under the amended framework, businesses will generally have up to five years from the end of the relevant tax period to request a refund of a credit balance or use that balance to settle tax liabilities, with targeted flexibility in specified cases where credits arise late in the cycle.

Transitional relief is also available for certain older credits around the changeover, which can help businesses address legacy positions in an orderly way. Dhruva said these changes reduce the risk of credits remaining unresolved on the balance sheet, improve cash flow planning, and encourage clearer internal ownership of refund positions.

Ujjwal further added, “The UAE has introduced a more robust operating framework for credit balances and refunds in line with international best practices. The message is simple: know your credits, map the deadlines, and file claims that are clear, complete, consistent, and easy to validate.”

Dhruva advised UAE businesses to act now with a finance-led approach. This starts with building a central credit-balance register by tax type and tax period, assigning an accountable owner, and tracking action dates so credits are either utilised or claimed in time. Businesses should also treat refund submissions as audit-ready files by preparing reconciliations, supporting documents, and a concise explanation of how the credit arose and why the amount is correct before submitting, rather than rebuilding the file after queries begin. In parallel, companies should prioritise older credit positions to assess whether they fall within the transitional relief window and avoid last-minute filings.

The firm also advised businesses to monitor any binding directions issued by the FTA and align their tax positions, documentation, and system settings accordingly to minimize interpretational differences and strengthen consistency over time.

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The StashAway Story and the Future of Digital Investing

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By Srijith KN, Senior Editor

Financial Integrator

Michele Ferrario, Co-Founder and CEO

StashAway’s journey began when Co-founder and CEO Michele Ferrario found himself frustrated and dissatisfied with the investment landscape marked by high fees and a lack of transparency. By age 35, his corporate career had provided him with substantial savings — yet when he approached his banks to invest in a portfolio of ETFs, he was sold expensive products that didn’t fit his needs.

This frustration inspired him to create a platform that would simplify investing while providing access to sophisticated financial products. In July 2016, he, along with the other two co-founders, came together, and by July 2017, after navigating regulatory requirements, StashAway was launched in Singapore.

“Stash,” as the word suggests—meaning to store something safely for future use—perfectly reflected what he wanted to achieve for himself. Over the past nine years, that personal need has grown into a company of more than 200 professionals, operating across five regions through a single, centralized technology platform.

Today, StashAway stands out as a pioneer in digital wealth management. The company leverages technology and deep investment expertise to offer accessible, low-cost alternatives to traditional wealth management, with a particular focus on private markets. Its approach has resonated with clients and positions the firm to benefit from regional economic growth and an increasingly digitally savvy population.

In the UAE, StashAway operates from the DIFC and has extended its presence to Malaysia, Thailand, and Hong Kong, with a chief investment officer based in Hong Kong overseeing investment strategies.

Democratizing Access to Investments

The company’s core strategy revolves around democratizing access to sophisticated investments. Private markets, which historically deliver higher returns at lower volatility, are central to this approach. By making private market products for a fraction of traditional minimums, StashAway removes the barriers that have long prevented high-net-worth individuals from participating in this fast-growing asset class. The platform also emphasizes transparency, with fees typically 50–75% lower than competitors, avoiding the hidden charges common in conventional wealth management products.

In public markets, StashAway offers an ETF-based, globally diversified portfolio called General Investing. The General Investing portfolio uses a proprietary investment strategy called ERAA (Economic Regime Asset Allocation). They have recently launched Sharia Global Portfolios, offering the same approach in a Sharia-compliant format. These Flexible Portfolios allow customers full control to create their own allocations using ETFs—either by using an existing template or building a portfolio entirely from scratch.

Capitalizing on the UAE Market

The UAE market presents a unique opportunity for StashAway. The region is home to a digitally engaged population with significant underinvested wealth. While 81% of financial wealth in the UAE is investable, nearly half remains in cash, losing value to inflation. StashAway’s platform appeals to a diverse range of clients, from seasoned executives to younger retail investors, aligning perfectly with regional growth initiatives like Dubai 2033, which targets strong GDP growth and population expansion.

Nino Ulsamer-Co-Founder and CTO

A Comprehensive, Client-Focused Approach

What sets StashAway apart is its comprehensive, client-focused approach. Its offerings include globally diversified portfolios, flexible build-your-own options, Sharia-compliant solutions, thematic strategies, and access to private equity, infrastructure, and private credit for accredited investors. The platform’s investment philosophy is long-term, balancing risk and reward according to individual goals, while its high service standards ensure responsive client engagement. And thus far I have been having a frictionless digital experience and went through a quick onboarding process. Client acquisition is primarily driven online, with dedicated advisors for high-net-worth clients under StashAway Reserve. Other users can engage through the app and are supported by StashAway’s responsive client experience team through email, phone call, or WhatsApp.

Shaping the Future of Digital Investing

As the UAE continues to attract global wealth, its wealth management landscape is becoming increasingly digital, with affluent investors seeking alternative investment opportunities. In an industry often criticized for opacity and complexity, StashAway is redefining investing by making it more transparent, accessible, and tailored to the modern investor. By combining advanced technology, strategic insight, and personalized solutions, the company is not just managing wealth—it is shaping the future of digital investing in the UAE and across the region.

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The Brief:

StashAway is a digital investment platform that was launched in 2017 to empower people to build and protect wealth in the long term. Offering simple, intelligent, and cost-effective investment and cash management solutions, StashAway has led the way in transforming the way people invest and grow wealth. Today, StashAway operates in five markets, Singapore, Malaysia, Hong Kong, the UAE, and Thailand, with billions of dollars in assets under management. The company was recognised by The World Economic Forum as a Technology Pioneer in 2020 and ranked among CNBC’s World’s Top Fintech Companies in 2023, 2024, and 2025.

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