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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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Financial

Al Masraf and Moody’s Sign Strategic Agreement to Strengthen Risk Intelligence and Credit Capabilities

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Al Masraf has signed a strategic agreement with Moody’s, a global provider of financial intelligence and risk assessment, marking an important step in strengthening the Bank’s risk management and credit capabilities through enhanced data, insights and technology.

The agreement was formalized during a signing ceremony held in Abu Dhabi, bringing together senior leadership from Al Masraf and Moody’s. The collaboration reflects both organizations’ commitment to leveraging advanced intelligence and risk expertise to support informed, data-driven decision-making in an increasingly complex financial environment.

As risks become increasingly interconnected and the financial landscape continues to evolve, access to timely, reliable and actionable intelligence is becoming essential for financial institutions. Through its combination of data, intelligence, risk expertise and technology, Moody’s helps organizations better understand interconnected risks.

The partnership will further support Al Masraf’s continued focus on strengthening its risk management framework, enhancing credit decision-making and building resilient, forward-looking capabilities that support sustainable growth.

Commenting on the occasion, Fuad Mohamed, CEO of Al Masraf, said: “At Al Masraf, we believe that sustainable growth is built on the strength of our ability to understand risk, anticipate change and make informed decisions. Our collaboration with Moody’s represents an important step in advancing our risk and credit capabilities through deeper intelligence, data and technology.”

He continued: “As the financial landscape continues to evolve, partnerships of this nature enable us to strengthen our resilience, enhance decision-making and create greater value for our customers and stakeholders. We look forward to building on this collaboration as we continue to shape a more agile, intelligent and future-ready Al Masraf.”

“We are delighted to partner with Al Masraf on an important step in modernizing its corporate lending operations. By bringing greater automation, efficiency, and insight to the credit journey, Moody’s is helping the bank build a future-ready operating model that enables faster, better-informed lending decisions, strengthens governance, and enhances risk management.” said Wael Jadallah, Managing Director, Head of Asia Pacific and Middle East at Moody’s.

Senior representatives from both organizations attended the signing ceremony.

Representing Al Masraf were Fuad Mohamed, Chief Executive Officer; Moataz Khalil, Chief Wholesale Banking Officer; Safeya Almarzooqi, Chief Credit Officer; Mirel Baila, Acting Chief Operating Officer; Rohit Kumar, Chief Risk Officer; and senior representatives from the Bank’s Wholesale Banking, Credit, Risk, Information Technology, Islamic Banking, Corporate Banking, Project Management and Business Management functions.

Representing Moody’s were Wael Jadallah, Managing Director, Head of Asia Pacific and Middle East; Brendan Gavaghan, Senior Director, Middle East; Raghavendra Katagade, Director, UAE; Blaine Connan, Director, UAE; Ali Abdullah, Director, UAE; and Anand Thirunellai Radhakrishnan, Senior Director, Middle East & Europe.

The agreement underscores Al Masraf’s commitment to continuous innovation and adopting advanced capabilities that strengthen its ability to navigate an evolving risk environment, while supporting the Bank’s broader ambition to deliver sustainable growth and enhanced value to its customers and stakeholders.

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DO FISCAL STIMULUS MEASURES SUPPORT THE US MARKET GROWTH, AND IS A DEFAULT POSSIBLE?

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With the dirham pegged to the US dollar and UAE investors exposed to global markets, decisions made by the Federal Reserve and the US government can influence local borrowing costs, liquidity, and investment
sentiment. Michael Smirnow, Chief Investment Officer, Arabian Capital Gulf
After the global financial crisis, U.S. authorities tried to stimulate the economy primarily through monetary measures: the Federal Reserve cut interest rates to zero and launched quantitative easing (QE) for the first time, purchasing assets to provide market participants with liquidity. As a result, the Fed’s balance sheet grew to USD 8 trillion by 2021. However, between 2008 and 2020, the U.S. economy did
not experience rapid growth, and inflation regularly remained below the target level. Everything changed in 2020, when the government entered the stimulus fray for the first time in many years. While the Fed’s accommodative monetary policy primarily helped large banks and market participants, at the onset of
the pandemic the U.S. government began distributing money to households and increasing budget expenditure across nearly all areas. Compared with monetary measures, these fiscal stimulus measures proved to be a significantly more powerful tool for stimulating the economy; however, they increased
government debt by the aforementioned 61%. Against this backdrop, we expect the next few years to be shaped primarily by fiscal stimulus, with
government action, rather than the Federal Reserve, becoming the key factor for investors. Indeed, while the private sector ran large deficits before 2008, the deficit now lies with the government, while private-sector indebtedness is declining. In the years following the pandemic, the largest government deficits coincided with the strongest growth in financial markets. This is unsurprising, since a public-sector deficit becomes private-sector income. This dynamic enabled the U.S. economy to remain resilient in 2023-2024 despite the Fed’s record pace of interest-rate increases. Whichever U.S. political party is in power will continue along this path;

Trump is also doing the same through legislation known as the “Big Beautiful Bill.” As long as inflation in the United States remains under control, this race will continue.
The current balance between monetary and fiscal stimulus vividly illustrates this argument. On the one hand, the U.S. Federal Reserve is adopting an increasingly neutral stance and is clearly in no hurry to cut interest rates or introduce new stimulus programmes. On the other hand, the Treasury is entering the fray: as yields on long-term U.S. bonds confidently exceed 5%, the Treasury has launched a program to buy back its long-term debt. In effect, this gives the bond market the same kind of stimulus the Fed previously delivered.

Thus, the balance of power is changing, but the direction remains the same: the United States still needs accommodative monetary conditions. If these are not achieved through monetary measures, they will be achieved through fiscal ones.
(Arabian Gulf Capital (AGC) holds a Category-1 Investment Firm license issued by the Central Bank of Bahrain and provides tailored investment solutions to individual, corporate, and institutional clients.)

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Navigating Growth and Liquidity: The Shift to Predictive Credit Intelligence in the GCC

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As GCC businesses expand into new markets and increasingly complex supply chains, traditional credit assessment is giving way to a more predictive approach. In this interview with Mohamad Jomaa, CEO and Country Manager for GCC and Egypt at Coface, we explore how real-time data, AI and early-warning intelligence are helping CFOs anticipate payment risk, protect working capital and make more confident decisions across customers, suppliers and markets.

What is driving the shift from relationship-based credit decisions to predictive credit intelligence among CFOs in the GCC?

Relationships remain fundamental to business in the GCC and will continue to be. What has changed is the speed at which companies are expanding into new sectors, markets, and supply chains. As organizations grow beyond their traditional networks, finance leaders need additional tools to assess customers, suppliers, and partners they may not know well.

Today’s CFOs are increasingly complementing business relationships with data-driven insights. They need greater visibility not only into credit risk, but also into supply chain dependencies, corporate ownership structures, payment behavior, and potential vulnerabilities across their ecosystem.

Predictive intelligence provides that forward-looking perspective. It helps businesses make faster and more informed decisions, strengthen due diligence processes, identify opportunities, and anticipate risks before they impact cash flow, operations, or growth plans.

What trends are you currently seeing in payment delays and corporate defaults across the UAE and Saudi Arabia?

The overall economic outlook in both the UAE and Saudi Arabia remains positive, supported by ambitious investment programs and continued economic diversification. At the same time, businesses continue to face uneven market conditions across sectors.

Drawing on Coface’s unique experience as a global trade credit insurer, we monitor payment behavior, claims activity, and credit events across millions of companies worldwide. What we are seeing today is not necessarily a significant increase in corporate failures, but rather signs of pressure on working capital in specific industries.

Payment delays have become more common in sectors exposed to longer project cycles, margin pressure, or supply chain disruptions. For finance leaders, the challenge is distinguishing between temporary liquidity constraints and deteriorating credit quality. This is where access to real-time payment data and early warning indicators becomes particularly valuable.

How can better credit intelligence improve cash flow, working capital, and overall financial resilience?

Better intelligence enables businesses to make more informed decisions across the entire customer and supplier lifecycle. By combining financial information, payment behavior, sector analysis, ownership data, Country Risk Assessments, Sector Risk Assessments, and ongoing monitoring, organizations gain a much clearer view of both risk and opportunity.

This has a direct impact on cash flow and working capital. Businesses can identify signs of financial stress earlier, reduce exposure to overdue accounts, prioritize collections efforts, and allocate credit more effectively. Access to real-time information and early warning indicators allows companies to act before issues translate into cash flow challenges.

Increasingly, however, financial resilience is not only about customer risk. It is also about understanding vulnerabilities across the supply chain. A disruption involving a key supplier, contractor, or logistics partner can have a significant impact on operations, costs, and liquidity. Better intelligence provides greater visibility into these critical dependencies, helping organizations identify concentration risks, assess the financial health of strategic partners, and strengthen business continuity planning.

As companies expand into new markets and engage with new customers, suppliers, and partners, they need confidence in who they are doing business with. Access to reliable data on ownership structures, financial health, payment behavior, sector outlooks, and country risk helps organizations make better-informed decisions and reduce uncertainty when entering new commercial relationships.

. What warning signs should finance leaders monitor before extending credit to new customers or entering unfamiliar markets?

Financial statements remain important, but they only tell part of the story. Finance leaders should also evaluate payment behavior, ownership structures, management stability, sector outlooks, supplier concentration, and exposure to geopolitical or regulatory risks.

One of the most valuable early warning indicators is a deterioration in payment behavior. In many cases, companies begin showing signs of financial stress long before it becomes visible in published financial statements.

Similarly, supply chain concentration risks should not be overlooked. A business may appear financially sound while remaining highly dependent on a small number of customers, suppliers, or projects. Understanding these dependencies is an increasingly important component of due diligence.

Effective credit decisions require a broader assessment of the business ecosystem rather than focusing solely on traditional financial metrics.

This is why a combination of company information, payment behavior, Country Risk Assessments, Sector Risk Assessments, and supply chain intelligence is increasingly becoming an essential part of the decision-making process.

How are AI and predictive analytics changing the way organizations assess credit risk and make financing decisions?

Financial statements remain important, but they only tell part of the story. Finance leaders should also evaluate payment behavior, ownership structures, management stability, sector outlooks, supplier concentration, and exposure to geopolitical or regulatory risks.

One of the most valuable early warning indicators is a deterioration in payment behavior. In many cases, companies begin showing signs of financial stress long before it becomes visible in published financial statements.

Similarly, supply chain concentration risks should not be overlooked. A business may appear financially sound while remaining highly dependent on a small number of customers, suppliers, or projects. Understanding these dependencies is an increasingly important component of due diligence.

Effective credit decisions require a broader assessment of the business ecosystem rather than focusing solely on traditional financial metrics.

This is why a combination of company information, payment behavior, Country Risk Assessments, Sector Risk Assessments, and supply chain intelligence is increasingly becoming an essential part of the decision-making process.

What sectors in the GCC are showing the strongest opportunities, and where are the highest risks based on your data?

Our outlook combines insights from Coface’s payment experience data, claims observations, Country Risk Assessments and Sector Risk Assessments. Together, these provide a comprehensive view of the opportunities and vulnerabilities shaping the business environment across the GCC.

We continue to see attractive opportunities in sectors supported by economic diversification strategies, digital transformation, infrastructure investment, logistics development and the energy transition. These areas are benefiting from sustained investment, strong policy support and growing regional demand.

At the same time, businesses operating in sectors facing tighter margins, elevated input costs, project execution challenges or longer payment cycles require closer monitoring. What is important to remember is that risk is rarely uniform across an entire sector. Performance can vary significantly from one company to another depending on its financial strength, competitive positioning, customer base and exposure to broader supply chain dynamics.

Looking ahead, how do you see the role of predictive intelligence evolving within corporate finance over the next three to five years?

Over the next three to five years, predictive intelligence will become an integral component of decision-making across finance, procurement, sales, treasury, compliance, and risk management functions.

We expect companies to move beyond using intelligence solely for credit assessments and begin embedding it throughout the business. This includes supplier selection, customer onboarding, supply chain management, compliance checks, investment decisions, and strategic planning.

The organizations that will be most successful are those that can combine technology, data, and human expertise to obtain a holistic understanding of their business ecosystem.

In an increasingly interconnected world, success will depend not only on knowing who you do business with, but also on understanding the risks and opportunities across the entire value chain. Access to reliable, forward-looking intelligence will therefore become a key competitive advantage, helping companies grow confidently while remaining resilient in a rapidly changing environment.

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