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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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3 weeks ago

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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

CFI Partners with Saadiyat Nights as Part of Its Collaboration with DCT Abu Dhabi

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3 hours ago

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January 17, 2025

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CFI

CFI Financial Group is proud to announce its official partnership with Saadiyat Nights, as part of CFI’s strategic partnership with the Department of Culture and Tourism – Abu Dhabi (DCT Abu Dhabi). This collaboration underscores CFI’s commitment to supporting its local community and providing its clients with unforgettable cultural and entertainment experiences in one of the world’s most dynamic destinations. 

Currently captivating audiences, the second edition of Saadiyat Nights is bringing legendary international artists, performers and fans together at the iconic open-air venue on Saadiyat Island. Running from December to February, this extraordinary series features iconic acts like Boyz II Men, Christina Aguilera, Robbie Williams, Michael Bublé, Leningrad, Ebi and Omar Khairat, with some already dazzling the stage and others eagerly awaited.

Through this collaboration, CFI will benefit from exceptional brand visibility at each event, while offering its clients premium access to performances and money-can’t-buy experiences, including exclusive Meet & Greet opportunities with some of these legendary artists.  

“Through this collaboration, CFI reinforces its brand presence and industry leadership by securing high brand visibility at each of the Saadiyat Nights events in Abu Dhabi, a key hub for culture and global connections,” said Hisham Mansour, Co-founder and Managing Director of CFI. “This partnership reflects our commitment to fostering meaningful connections, supporting cultural initiatives and providing our clients with opportunities to engage with world-class experiences that complement their journey with CFI.”

Through this partnership, CFI is proud to support Abu Dhabi’s position as a leading cultural destination in the region, while staying committed to its mission of providing traders with exceptional trading experiences and engaging with like-minded local communities.

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Financial

MultiBank Group Secures Court Victory as Judge Declares Von Der Heydt Claims as “Fictitious” and “Untenable”

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6 hours ago

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January 17, 2025

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MultiBank Group

MultiBank Group has achieved a significant courtroom victory in the Eastern Caribbean Supreme Court against Von Der Heydt Invest S.A. (VDH), a Von Der Heydt Group subsidiary, which had brought claims against MultiBank FX International Corporation (MBFX), a MultiBank Group entity, and its founder, Naser Taher.

The court described the allegations brought by VDH as ‘fictitious’ and ‘untenable’, labelling VDH’s pursuit of these matters as an “abuse of process.” The court ordered VDH to cover over USD$25 million in legal costs incurred by Mr. Taher and MBFX. 

The Honorable Justice Gerhard Wallbank’s decision rejected VDH’s claims and confirmed MultiBank Group’s adherence to transparency and integrity. Naser Taher, Founder and Chairman of MultiBank Group said: ‘The accusations levied against us by Von Der Heydt have always been unfounded, and this ruling is a testament to our strong adherence to the principles of fairness and lawful conduct.’

The court confirmed that the legal campaign by VDH and its affiliates over the past four years consisted of coordinated and unfounded allegations targeting MultiBank Group. The judgment also highlighted a “conspiratorial network” involving multiple parties.

A previous ruling by the court made in early 2024 compared the relationship between the Von Der Heydt Group, to the Bernie Madoff ponzi scheme.

This decision marks an end to VDH’s pursuit of claims against the MultiBank Group and runs parallel to the financial group’s broader collapse. Von Der Heydt Bank, a 250-year-old institution and VDH’s parent company, has surrendered its banking license and ceased to exist after being placed in liquidation by its founder Dietrich Von Boetticher. The court further commented on the plight of German noteholders allegedly represented by VDH, attributing their difficulties to mismanagement at the hands of the Von Der Heydt leadership.

A prior ruling by the London High Court found Colm Smith, CEO of CSM Securities, and his company in contempt of court for not adhering to a worldwide freezing order (WFO) obtained by MultiBank Group. This contempt stems from Smith’s failure to disclose assets related to a legal dispute involving Van Der Heydt Invest SA (VDHI), where significant losses were linked to investments in notes associated with the Multibank Index. His actions have raised the possibility of imprisonment as the court continues to address allegations of unlawful collusion against MultiBank Group, which are unfolding in various European courts.

MultiBank Group’s victory in the Eastern Caribbean Supreme Court further solidifies its position as a trusted leader in the financial derivatives market, operating under the oversight of 16 regulators across five continents and serving over one million clients worldwide. Naser Taher added: ‘We are delighted that the judiciary has recognised the baseless nature of these accusations and affirmed our global reputation for integrity and operational excellence. We remain steadfast in delivering the highest standards of financial services to our clients.’

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Features

Building businesses that last: Lessons from Dubai’s Startup Ecosystem

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1 week ago

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January 9, 2025

By

Culture Mapping

Dubai-based entrepreneurs and podcast hosts Konstantin Koloskov and Anastasia Davydova share lessons from 2024’s dynamic business landscape, exploring the power of collaboration, sustainable growth, and staying true to your vision amidst rapid change. Dubai in 2024 was a hub of energy and innovation, with startup founders raising capital, scaling rapidly, and embracing the city’s ever-changing landscape

As co-hosts of Culture Mapping, a podcast exploring the intersections of culture, entrepreneurship, and life in the UAE, we’ve had the privilege of looking at Dubai through a unique lens. Our conversations with inspiring guests—from startup founders to artists—have offered us fresh perspectives on the opportunities and challenges 2024 has brought.

At the same time, our collaboration on the podcast has been a powerful reminder of the strength found in partnerships. Beyond being co-hosts, we’re both entrepreneurs leading our own companies — Konstantin, the co-founder of Storm, a content studio, and Anastasia, the co-founder of Movingo, a relocation platform for businesses and talents moving to the UAE.

2024 was a challenging year for both of us, but it reinforced a key insight: the power of collaboration within teams and across industries and ventures. Supporting each other in our businesses while building the podcast together has opened new opportunities, sparked creative ideas, and brought energy to everything we do. We also saw This spirit of collaboration reflected in our podcast guests. Dubai in 2024 has been a hub of energy and innovation, with startup founders like those we interviewed raising capital, scaling rapidly, and embracing the city’s ever-changing landscape. Their stories reminded us how crucial it is to stay connected to a network of thinkers and doers who inspire and challenge you.

Key Lessons from 2024

  1. Stay Open to New Opportunities, But Don’t Lose Sight of Your Core Vision: One of our most memorable guests this year was Phillipo Minelli, a visionary artist who embodies this principle. While he sees the growing potential of the UAE and its flourishing art scene, he stays grounded in the values of his work. Phillipo reminded us that growth and opportunity mean little if they compromise your core mission or beliefs.
  2. Prioritize Sustainable Growth Over Short-Term Gains: Felix Erdman, a businessman featured on our podcast, is a shining example of this lesson. His approach to building wealth with a long-term perspective—eschewing fleeting trends and buzz-worthy ventures—was inspiring. His story reinforced what we’ve learned firsthand in our businesses: thoughtful, strategic growth is the foundation for lasting success.
  3. Collaboration Drives Innovation: Dubai’s vibrant, multicultural energy fosters collaboration in a way few places can. Whether it’s the three startup founders we interviewed—who shared how working with the right partners helped them scale—or the creative synergies we’ve experienced in our work, it’s clear that great things happen when ideas are shared and connections are made.

Looking Ahead to 2025

As we prepare for the New Year, we’re embracing the lessons of 2024 with a renewed focus on intentional growth. The global economic shifts have made us even more mindful of how we approach risk and investment. Innovation matters, but so does sustainability. To our fellow entrepreneurs, here’s the advice we’ll be taking with us into 2025:

  1. Keep an eye on new horizons, but stay true to your vision.
  2. Prioritize sustainable growth over chasing quick wins.
  3. Value collaboration—it’s a game-changer.

Dubai continues to be a city where ambition meets possibility, and we’re excited to see how it will evolve in the year ahead. For us, the focus is clear: building businesses that last, telling stories that matter, and embracing the power of collaboration to make it all possible.

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