Financial
With DMTT coming into effect on Jan 1st, 2025, a tax expert explains everything businesses in Bahrain need to know
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.
Financial
UAE’S R&D TAX CREDITS COULD UNLOCK SIGNIFICANT VALUE FOR CONSTRUCTION SECTOR

Construction companies across the UAE may be overlooking one of the most valuable outcomes of the country’s new R&D Tax Credit regime. Introduced under Ministerial Decision No. 24 of 2026 and effective from 1 January 2026, the framework offers credits of 15% to 50% on qualifying R&D expenditure. Yet, according to Dhruva, a Ryan Affiliate, many construction businesses have yet to identify the full extent of qualifying activity or put in place the processes required to claim these benefits.
As one of the UAE’s most economically significant sectors, construction is uniquely positioned to benefit from the regime. Innovation in this sector is continuous, spanning materials, construction methods, digital tools and safety systems but much of it has historically not been classified or documented as R&D.
“The construction sector innovates constantly, in materials, in methods, in software, in safety. The challenge is that much of this activity has never been labelled R&D, and therefore never documented as such. That is precisely where value is being left on the table. Companies that begin mapping their qualifying activities now, and build the evidence trail the regime demands, will be the ones positioned to capture this benefit when it matters most,” said Nimish Goel, Leader Middle East, Dhruva, Ryan LLC Affiliate.
To qualify under the regime, R&D activities must meet five criteria aligned with the OECD Frascati Manual: they must be novel, creative, uncertain in outcome, systematic, and transferable or reproducible. For construction businesses that approach innovation with defined objectives, structured experimentation and documented results, a wide range of activity meets this threshold.
In practice, qualifying activity in the construction sector can include the development of advanced materials such as low-carbon concrete and smart composites, experimentation with modular construction techniques and prefabrication systems, and proprietary software development for Building Information Modelling (BIM), digital twins and AI-driven project management. Sustainability innovation also qualifies, including net-zero building systems and passive cooling technologies suited to UAE conditions, as does the adoption of robotics and drone-based construction and inspection methods.
The critical distinction lies between routine construction activity and genuine R&D. Applying an established methodology to a new project does not qualify. Systematically resolving technical uncertainty through experimentation and documenting that process does.
A distinguishing feature of the UAE regime is its dual-threshold structure. Each credit tier requires businesses to meet both a minimum level of qualifying expenditure and a minimum average R&D headcount. The first AED 1 million of qualifying spend attracts a 15% credit with at least two R&D staff; spend between AED 1 million and AED 2 million qualifies for 35% with at least six staff; and spend between AED 2 million and AED 5 million attracts 50% with at least fourteen. Where headcount thresholds are not met, the applicable credit rate is reduced accordingly.
For construction companies, this makes workforce planning integral to tax strategy. Specialist roles including materials scientists, structural engineers working on novel challenges, proptech developers and robotics engineers not only drive innovation but also determine access to higher credit tiers. Staff costs additionally benefit from a 30% uplift in qualifying expenditure, further strengthening the case for building dedicated R&D capability.
“This is not just a tax incentive; it represents a structural shift in how innovation is recognised within the construction sector. Businesses that act early will not only benefit financially but also strengthen their long-term technical capabilities,” added Nimish.
The regime places significant emphasis on contemporaneous documentation and structured processes. Pre-approval from the relevant authority is mandatory, and businesses must maintain detailed technical records of R&D objectives, methodologies, experiments and outcomes for a period of seven years. For construction companies, this requires embedding R&D tracking into project workflows from the outset, rather than attempting to reconstruct evidence retrospectively.
Construction groups operating centralised engineering or shared technology platforms should also review their structures carefully. Intra-group transactions are excluded from qualifying expenditure, making it critical to ensure that R&D costs are appropriately allocated at the entity level.
“The UAE’s construction sector is building the physical infrastructure of a knowledge economy. It is fitting that those who innovate within it now have access to the same calibre of R&D incentive as their counterparts in technology or manufacturing. The question is not whether to engage, but how quickly companies can build the processes to do so effectively,” concluded Nimish.
Financial
HOW GLOBAL SECURITY AND VALUABLES LOGISTICS PROVIDERS ARE ADAPTING OPERATIONS AMID RISING GEOPOLITICAL TENSIONS

Nader Antar, EVP & President – APAC, IMEA & Brink’s Global Services
Much like a stable internet connection or accessibility to clean water, when we consider global finance we tend to take continuity for granted – until it is tested. Capital moves, liquidity flows, and billions in high-value assets cross borders each day, all with an expectation of certainty. Yet courtesy of the ongoing conflicts across the region, that certainty is being challenged in real time.
The Iran war is both reshaping geopolitical dynamics and disrupting the very corridors through which global trade and financial flows depend. Volatile energy markets, heightened concerns about broader economic spillovers, and early signs of how critical trade arteries such as the Strait of Hormuz can suddenly turn stability to systemic risk have sharpened the focus on resilience across the Gulf.
Of course, even amid these heightened tensions, the region continues to project stability, with governments advancing long-term infrastructure and supply chain strategies. Saudi Arabia’s new Logistics Corridors Initiative – which among its objectives aims to establish Red Sea routes capable of bypassing Hormuz entirely – reflects a deliberate approach to ensure the movement of goods, and especially the movement of value, remains uninterrupted.
Within this environment, the transport of high-value assets – banknotes, precious metals, and other commodities – has come under increased scrutiny. These flows are deeply embedded in the functioning of financial systems, linking central banks, commercial institutions, and global markets. When disruption occurs, the consequences extend beyond delayed shipments and can impact everything from liquidity to market confidence to operational continuity.
The question then, during a period of geopolitical conflict, is not whether disruption will occur, but how quickly and smoothly systems can adapt when it does. At Brink’s, our approach to this particular challenge is anchored in three core principles: Infrastructure, diversification, and visibility.
Infrastructure is the foundation of resilience. A globally distributed network of high-security facilities across major trade hubs ensures continuity by allowing rapid shifts when disruptions occur. Whether that is in the UAE, Switzerland, Singapore, or the United States, these facilities enable valuable commodities to be securely stored, repositioned, and mobilised as conditions evolve. In an unpredictable environment, the ability to absorb shocks and shift assets quickly without compromising security or compliance is crucial.
Diversification ensures flow flexibility. Traditional logistics models, often optimised for efficiency along fixed corridors, are no longer sufficient. Today’s operating environment demands multi-route, multi-modal strategies that allow shipments to be rerouted rapidly when disruptions occur. By integrating storage and transport into a single, coordinated system, it becomes possible to maintain continuity even as specific routes or markets face constraints.
Visibility, however, is what brings resilience into focus. Real-time monitoring across operations provides the situational awareness needed to anticipate risks and respond proactively. Through centralised platforms, our teams maintain continuous oversight of shipments, facilities, and transport networks. This level of transparency goes far deeper than simply tracking assets; it is about enabling faster, more informed decision-making in moments where timing is critical.
The UAE offers a compelling example of how these principles come together in practice. As one of the most stable and strategically positioned logistics hubs in the world, the Emirates has built an ecosystem defined by advanced infrastructure, strong regulatory frameworks, and deep connectivity across global trade corridors. In many respects, operations remained business as usual throughout these past couple of months. Yet this continuity is not accidental; it is the result of deliberate investment in systems designed to withstand disruption — even when the country found itself pulled into what might yet be one of the most consequential conflicts in recent history.
Beyond transport, the scope of secure logistics continues to expand. From safeguarding high-value assets at major international exhibitions to ensuring the uninterrupted availability of cash through extensive ATM networks, resilience must be embedded across the entire financial ecosystem. In markets such as India, innovation is also reshaping how cash and digital systems interact, creating new models that enhance both security and accessibility.
None of this happens in isolation. Secure logistics operates within a broader framework that depends on close coordination with regulators, customs authorities, and law enforcement agencies. These partnerships are essential to maintaining compliant, uninterrupted cross-border flows, particularly during periods of heightened geopolitical tension.
What we are witnessing today is a broader transformation in how the logistics sector approaches risk. The emphasis is moving from efficiency to adaptability, from linear supply chains to dynamic, interconnected networks. Resilience, flexibility, and visibility are now considered non-negotiables.
Global trade will continue to evolve, shaped by shifting geopolitical dynamics and emerging economic corridors. But one constant will remain: The need for trust. It is only with this that assets will move securely, that systems will hold under pressure, and that continuity will be maintained.
In the end, the true measure of a network — be it global finance, logistics, or indeed telecommunications — is not how it performs when conditions are stable, but how effectively it responds when they are not.
Financial
ROSTRO GROUP POSITIONS THE UAE AS A STRATEGIC HUB FOR INSTITUTIONAL MARKET INFRASTRUCTURE

Exclusive interview with Michael Ayres, Group CEO & Partner at Rostro Group
What strategic factors made the UAE the next major market for Rostro?
The UAE represents a very deliberate choice for us, rather than just a natural expansion step. What sets it apart is the alignment between ambition, regulation, and execution. You have a government that is actively shaping the future of financial services, a regulatory environment that is evolving at pace, and a private sector that is willing to innovate and adopt new models. That combination is rare.
From a strategic standpoint, the UAE sits at the intersection of global capital flows. It connects East and West, and increasingly serves as a base for institutional participants looking to access both developed and emerging markets. We’re seeing a growing presence of hedge funds, family offices, and proprietary trading firms establishing themselves here, which naturally increases demand for more sophisticated infrastructure around liquidity, execution, and risk management.
For Rostro, that is exactly where we operate. We’re not just building products; we’re building infrastructure that supports how modern markets function. The UAE gives us the platform to do that at scale, while remaining close to clients who are actively shaping the next phase of the industry. It’s a market that is not only growing, but evolving, and that makes it an ideal environment for long-term investment.
How is Rostro managing liquidity sourcing in the UAE given the current market environment?
The current market environment has made one thing very clear: liquidity is no longer just about access; it’s about resilience. Periods of volatility, geopolitical uncertainty, and concentrated positioning expose the limitations of traditional liquidity models, particularly those that rely heavily on internalisation or a narrow set of counterparties.
Our approach is to move away from that dependency and towards a more diversified, structured model. We combine OTC liquidity with direct access to exchange-traded markets, allowing us to provide clients with both flexibility and transparency. This is particularly important in volatile conditions, where pricing integrity and execution certainty become critical.
We’re also seeing a clear shift in client behaviour. Institutional participants are becoming more conscious of execution quality, counterparty exposure, and the underlying mechanics of how liquidity is sourced. That is driving increased interest in exchange-traded products, as well as institutional-grade crypto liquidity, where market fragmentation has historically created inefficiencies.
By building infrastructure that brings these elements together – across OTC, exchange-traded derivatives, and digital assets – we’re able to offer a more stable and consistent execution environment. The objective is not just to perform in favourable conditions, but to remain reliable when markets are under pressure.
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